Satisfactory Academic Progress Standards

1. Satisfactory Academic Progress Standards Claire “Micki” Roemer School Services and Training Federal Student Aid Dan Klock Federal Student Aid

2. Our Agenda • Statutory and Regulatory Requirements • Tools • Q’s & A’s • Discussion

3. Statutory and Regulatory Requirements • Higher Education Act (HEA) • 484(a) and (c) • CFR • 668.14 PPA • 668.16 (c) SAP • 668.32 Student Eligibility • 668.34 SAP • 668.42 (c) Consumer Information

4. Statutory Requirements • Sec 484 (a)(2) • In order to receive Title IV (TIV) aid • The student must be maintaining Satisfactory Academic Progress (SAP) in the program of study in accordance with (c)

5. Statutory Requirements • Sec 484(c) – Satisfactory Academic Progress • The institution must determine at the end of the second AY • That the student has a “C” average, or equivalent, or • Academic standing consistent with the requirements for graduation

6. Statutory Requirements • Sec 484(c) – Satisfactory Academic Progress • The school must have a policy for undue hardship for; • The death of a relative • Personal injury or illness of the student • Special circumstances as determined by the school

7. Regulatory Requirements • 34 CFR 668.14 Program Participation Agreement (a)(1) and (b)(1) • The eligible and participating institution agrees to comply with the General Provisions Regulations (Part 668) and to comply with all program regulations

8. Regulatory Requirements • 34 CFR 668.16 (e) Satisfactory Academic Progress • Each school must establish, publish, and apply reasonable standards for measuring SAP • Same or stricter than school’s other standards for students in the same program

9. Regulatory Requirements • 668.16 (e) Satisfactory Academic Progress – Must include the following elements • Qualitative component – grades • Quantitative component – max timeframe • Consistent application w/in categories of students • Provide the timeframe for the determination of SAP • Appeals procedure • Provide procedures to re-establish SAP

10. Regulatory Requirements • 34 CFR 668.32 (f) Student Eligibility • In order to be eligible for TIV funds • The student must be maintaining SAP

11. Regulatory Requirements • 34 CFR 668.34 SAP • Program > 2 years • Student must have “C” average after 2nd yr, or • Standing consistent with graduation requirements • Exceptions • Death of family member • Injury or illness of student • Other special circumstances • Must make SAP determination at least 1/yr

12. Regulatory Requirements • 34 CFR 668.42 Consumer Information • Requires that the standards to maintain SAP must be described • Criterion by which someone who has failed the SAP standard may re-establish SAP

13. Federal Requirements • Every institution must have in place Satisfactory Progress Standards. • An institution must make a determination of whether each student has met the SAP requirements at least the lesser of once every academic year (or ½ the length of the program if < 1 AY).

14. SAP Standards must include: • A qualitative component. • The law specifies that by the end of the second academic year (regardless of how many credits the student has accrued), the student must have a C average or its equivalent or have an academic standing consistent with the requirement for graduation from the program.

15. SAP Standards must include: • A quantitative component: • You must set a maximum time frame in which a student is expected to complete a program. •   For an undergraduate program the time frame cannot exceed 150% of the published length of the program measured in academic years or terms, credit hours attempted, or clock hours completed, as determined by your school.

16. SAP Standards must include: • For example: • School A requires GPA of 2.0 for each AY • School B has a graduated scale • Both schools have a max timeframe of 6 years for a 4 year degree program

17. SAP Standards • Another example:

18. All periods of a student’s enrollment must be included in determining the qualitative and quantitative measures, even those periods where the student attended but did not receive FSA funds;

19. Exceptions may include: • If a school has in its policy, the allowance for a student who switches degree programs to not count for SAP those grades earned and credits attempted in the old major, although minimally, any courses that apply to the new program must be counted. • For transfer students a school must at least count those transfer credits that apply towards the current program (although a school may count all work from a previous school).

20. The Standards Should Address: •  Rules for both undergraduate and graduate students who change majors, as well as students who seek to earn additional degrees. • Specific policies defining the effect of incomplete course grades, withdrawals, repetitions, and non-credit remedial work.

21. Repeat/ Delete • When a school has a written policy that allows only the highest or the most recent grade to be counted, or both credits and grades from previous attempts to be deleted, the FA may exclude the grade for the prior attempt from the qualitative SAP standard but it must count the credits attempted when considering the quantitative SAP standard.

22. Standards Should Address: • Specific procedures for students to appeal a determination when they are not making satisfactory academic progress; • Specific procedures for a student to re-establish that he or she is maintaining satisfactory progress.

23. The Standards Must: • Be published; • Applied equally to all FSA programs and to all FSA recipients within identifiable categories of students (such as full or part-time, undergraduate or graduate, or students in different academic programs); • Be at least as strict as that used for students who do not receive FSA.

24. FSA Assessment Tool A Tool to Assist:

25. Does your Basic Consumer information contain the following information about your school? • The names of associations, agencies, and/or governmental bodies that accredit, approve, or license the school and its programs, and the procedures by which a student may receive a copy for review of the school's accreditation, licensure, or approval. • Special facilities and services available to disabled students. • The costs of attending the school (tuition and fees, books and supplies, room and board and applicable transportation costs, such as commuting) and any additional costs of the program in which the student is enrolled or has expressed an interest. • A statement of the requirements for the return of Title IV funds when a student withdraws from school, information about any refund policy with which the school must comply, and the requirements for officially withdrawing from the school. • The degree programs, training, and other education offered. • The availability of a GED program, if the school admits students who do not have a high school diploma or equivalent. • The instructional, laboratory, and other physical plant facilities associated with the academic programs. • A list of the faculty and other instructional personnel. • The satisfactory progress standards that must be maintained.

26. Consumer Information • Your Satisfactory Academic Progress Standards are part of your basic Consumer Information Requirements. • You satisfactory academic progress standards must be available to enrolled or prospective students. • This information can be provided through brochures, information on web sites, etc.

27. Q’s & A’s Q: Some schools have academic amnesty procedures where the student can have credits attempted and grades earned in previous semesters excluded from the GPA calculation. Is this permissible for the purposes of SAP? A: Our rules do not allow for the exclusion of of credits attempted and/or earned in the determination of SAP within the student’s program of study at the school.

28. Q’s & A’s Q: May a school exclude courses that a student has earned a grade of “W” (withdrawn)? A: Many schools have an “Add/Drop” period in the beginning of the term during which students can add or delete courses which will not adversely impact SAP. However, after the Add/Drop period closes, all grades and credits attempted must be considered in the SAP determination.

29. Q’s & A’s Q: How does the 150% rule work for students who transfer in credits earned previously at other schools? A: We have told schools to subtract the number of previously earned credits accepted into the current program from the total required for program completion and then apply the 150%. For example, Student A has earned 100 credits at other schools. When A enrolls at Fed Tech 24 of the 100 credits are accepted toward the 120 credits required to complete the program. Therefore, 76 X 150% = the student has a maximum of 114 credits to earn the remaining 76 credits.

30. Q’s & A’s Q: When a student is denied TIV aid due to not making SAP is the student required to appeal? A: 668.16(e)(5) states that an institution must “provide specific procedures under which a student may appeal a determination that the student is not making satisfactory academic progress.” Not all students will appeal their suspension; therefore an appeal is not required. However, the process must be available for all students who want to appeal their suspension.

31. Q’s & A’s Q: May a student automatically become eligible to receive federal aid without an appeal based upon performance subsequent to the suspension of TIV? A: 668.16(e)(6) states that the school must “provide procedures to re-establish that the student is maintaining SAP. Just to clarify – a student APPEALS the suspension of TIV aid for failing to maintain SAP by submitting information for the school to make a determination of whether the suspension should be upheld or cancelled. A student who requests to re-establish TIV eligibility has taken courses without TIV aid and subsequently re-establishes SAP and therefore regains eligibility for TIV aid.

32. Q’s & A’s Q: If a student will not be able to complete his/her program within the 150% max timeframe is the school required to deny TIV aid before the end of the max time period? A: Yes

33. Q’s & A’s Q: Can a school have as a component of its SAP policy that the student is required to not attend for a period of time as a condition to re-establish TIV eligibility? A: For the purpose of re-establishing TIV eligibility the student must achieve the qualitative and quantitative requirements. Generally, suspending academic activity does not increase one’s GPA to the required minimum. Absence does not restore elig.

34. Q’s & A’s Q: May a school average the number of credits required for the establishment of the 150% maximum timeframe when it has multiple programs of varying lengths? A: No – reasonable standards must be established for students in the same program, therefore the maximum timeframe must be established for each program recognizing the program’s length.

35. HERA Info • The Department has not yet issued regulations to implement the provisions of the Higher Education Reconciliation Act of 2005. Program participants, including institutions, lenders, and guarantee agencies, should implement the Act in accordance with sub regulatory guidance provided by the Department in Dear Colleague Letters and other materials until the regulations are published and effective. In general, the regulations will be effective 30 days after they are published in the Federal Register.

36. Q’s & A’s Q: Under the new grant programs (ACG and SMART), if a student appeals a SAP suspension and the appeal is granted, but the student has less than a 3.0 GPA, are the new grants restored also? A: Presumably the student is a second year ACG or SMART grant recipient. If the appeal is granted all TIV aid except the new grant would be awarded. Since a 3.0 is a requirement for the new grant, the student cannot establish eligibility for the ACG or SMART grant with < 3.0 GPA

37. Program Reviewer Checklist • Distribute copy and discuss

38. Questions Contact Information: Claire M. Roemer Email: claire.roemer@ed.gov Phone: (202) 377-3452 Dan Klock Email: dan.klock@ed.gov Phone: (202) 377-4026