In 2010, the U.S. Department of Education published new rules that impacted how colleges and universities administer many crucial aspects of the federal student aid programs. These “program integrity” rules covered 14 various areas, and while some have since either been amended or struck down by the courts, as in the case of gainful employment, colleges and universities continue to struggle with several of them. ECG has found through our work with our clients that the most problematic of the rules pertain to satisfactory academic progress (SAP) and Return of Title IV (R2T4) funds, related to both attendance and modules.
This article (part 1 of 3) discusses where we are with the program integrity rules as they pertain to SAP, and the challenges that colleges and universities still face.
Satisfactory Academic Progress
The objective of the SAP-related program integrity rules was to introduce consistent terminology as well as consistent monitoring of a student’s progress. To do this, the Department consolidated many of the SAP rules that were previously dispersed across sections of the regulations. In addition, the new rules specified requirements that were previously not mandated. Consequently, many offices had to rewrite long-standing institutional policies, which meant re-educating college staff as well as students, and redesigning internal tracking systems to accommodate new checks and balances. While there were significant changes, schools were still required to check SAP both from a quantitative (pace and maximum time frame) and qualitative (GPA) perspective – these requirements did not change!
These new rules also meant that institutions now had to make lots of decisions, such as at what intervals they would check SAP and whether they would allow students to appeal. These decisions were not easy, as they impacted both the financial aid office and students; in some cases, what benefited one did not necessarily benefit the other.
When Should You Check SAP and to Warn or Not?
If your school’s programs are at least one academic year in length, you have a choice about when to check SAP! You can check at the end of each payment period OR at least annually, in conjunction with a payment period.
If your school decides to check SAP after every payment period (rather than annually), you may utilize a warning period (but are not required to do so), without the student having to appeal, for one payment period (this is yet another decision the institution can make). If your school decides to implement a warning period, the student can use this time to correct the deficiency before actually losing aid eligibility. It is important to note, though, that by checking SAP at the end of each payment period, you would dramatically add to your financial aid staff’s administrative burden (when resources are already stretched). This is because you will be checking SAP two, three, or four times in a year, versus the required one time per year.
To Allow Appeals or Not to Allow Appeals… That is the Question
The program integrity rules allow schools to decide whether or not they will allow appeals. This decision must be addressed in the school’s policy and if your school will allow them, you must describe the process by which a student may reestablish financial aid eligibility. The rules are also more restrictive in terms of requiring that students provide a specific reason or basis for their appeal; permissible examples include: “death of a relative, an injury or illness of the student, or other special circumstances…” If the student will not be able to meet SAP even after the probationary payment period, the school needs to develop an academic plan for that student (see below).
If your school decides not to allow appeals, your policy must also address how a student may reestablish eligibility for Title IV funds.
We Need a Policy for That?!?
Schools that participate in the Title IV programs have long been required to have a SAP policy; however, the program integrity rules added additional items that must be included and they also proscribed how schools should review both SAP and SAP appeals. For instance, the policy “must not allow a student on financial aid probation for a payment period to receive Title IV, HEA program funds for the subsequent payment period unless the student makes SAP” or meets the terms of the student’s academic plan. It’s important for your school to review all of the regulatory requirements and ensure your policy addresses each of the required areas.
Speaking of an Academic Plan
Did you know that, if a student submits an appeal and it is not possible for the student to make SAP after one probationary period, your school must collect an academic plan? And that the plan, if followed, must ensure that the student is able to meet your school’s SAP standards by a specific point in time? And that if the student does not meet the plan, he/she is not eligible for financial aid for the subsequent payment period? These are all requirements of the appeal process as they relate to an academic plan.
The above issues are just some of the major “pain points” that ECG has observed in working with our school clients on the SAP-related program integrity rules. What other challenges and insights has your school experienced with these issues?
