1. Satisfactory Academic Progress Developing Academic Plans that Work Presentation Details

2. In this presentation we will review the SAP regulations; discuss the appeals process; review methods of administering Academic Plans; seek answers to the questions; – “What makes an acceptable appeal reason?”, – “How long should an academic plan last?”, – “What GPAs are too low?”, – “Should the student be evaluated mid-semester?”, – “How much responsibility should advisor’s take?”, – “Should a student be able to adjust his plan?”; and discuss ways to evaluate the success of academic plans and how to make improvements.

3. Points we will discuss: What is “Academic Progress”? SAP Regulations Common SAP Standards Institutional Academic Standards What makes a Valid Appeal? What’s a Reasonable Academic Plan? Does One Plan Fit All? When is a Graduation Plan Appropriate?

4. What is Satisfactory Academic Progress? When a student is 1)achieving a specific grade point average (GPA), or other comparable assessment measured against the norm, and 2)maintaining a specific pace of progression through an educational program; which indicates the student is able to complete the program within the maximum timeframe, as specified in regulations.

5. What is a SAP Policy? The consistent application of standards to all students determining whether an otherwise eligible student is making “satisfactory academic progress” in his or her educational program.

6. SAP Regulations HEA Sec. 484(c), 34 CFR 668.16(e) 34 CFR 668.32(f) 34 CFR 668.34 The SAP most recent regulations appear in the October 29, 2010, Federal Register.

7. SAP Regulations SAP Policy Rules SAP Reviews Consequences Financial Aid Warning SAP Measurements (Qualitative & Quantitative) Courses that don’t count for credit Appeals Probation Academic Plans Periods of Non-Enrollment or Periods without F.A.

8. SAP Policy Rules Must be at least as strict as your School’s Must apply consistently to all students in a category. You can have separate policies for: – Educational programs Degree Programs Majors – Years in School Freshmen Seniors – Educational Levels Graduates Undergraduates

9. SAP Regulations SAP Reviews Must Review Annually (once every 12 months) Must correspond with end of a payment period (Fall, Spring, Summer, etc…) If >1 year, – may call for reviews after each payment period If you do…You must review after Summer – may review even more frequently (mid-term, monthly, bi-weekly, etc…) – must still have end of payment period review At end of 2 nd year: Must review Qualitative Standard (ie GPA)

10. SAP Regulations Consequences Two standards are measured If not meeting 1 of those standards Becomes Ineligible for FSA Funds May lose eligibility for other aid funds – State Grants and Scholarships – National Guard benefits – Reserves Benefits You must notify students of results of evaluations and affect on FSA eligibility.

11. Financial Aid Warning Optional Only if you review each payment period If after 1 payment period, not meeting SAP May put student on FSA Warning Don’t have to allow appeals Student may continue to receive FSA funds Lasts for one payment period If still fails SAP after, loses aid eligibility Can’t be used for schools that review annually

12. SAP Measurements Qualitative: An appropriate qualitative measure that is comparable against a norm that is consistent with your school’s graduation requirements Quantitative A student is ineligible when it becomes mathematically impossible for him to complete his program within 150% of the length of the program.

13. SAP Regulations SAP Measurements Qualitative Standard: Must be defined for each evaluation period Must be Cumulative (can also have pay period requirements) Usually GPA – Best Practice: GPA used for graduation purposes – Others: Major GPA, Collegiate GPA, LIFE GPA Must be a “C” or equivalent at end of 2 nd year OR Must have GPA consistent with school’s graduation requirements: IE escalating scale. Common Standard: 2.0 GPA (C average)

14. SAP Regulations SAP Measurements Escalating GPA: Can allow a GPA below a C average after 2 nd year, but… Must document that a student with < C avg. could still meet the standards required for graduation complete degree within the Maximum Time Frame still meet the Quantitative Standards (Pace) Example: requires a cumulative GPA of – 1.50 after the 1 st year, – 1.75 after the 2 nd year, – 2.0 after the 3 rd year (C average)

15. SAP Regulations SAP Measurements Qualitative Standard and Special Cases: Remedial Coursework: – Must be counted in Qualitative in some way – Doesn’t have to be included in GPA – Could be simply Pass/Fail Transfer GPAs – Are the grades used for Graduation Purposes? – Will they prevent entrance into degree program?

16. SAP Measurements Qualitative Standard and Grade Forgiveness AKA: Amnesty, Renewal, Replacement No FSA provisions for ignoring a grade School must include all grades from all courses Exception: School can elect to ignore courses not applicable to the student’s major (ie not accepted for transfer or when major changes) Student can appeal to have academic plan that ignores them (not forgiven, compensated for).

17. SAP Regulations SAP Measurements Quantitative Standard: Maximum timeframe: – 150% of the published length of the program Credit Hours: # Credits Required x 1.5 Clock Hours: # Hours Required x 1.5, as calendar time. Graduate Programs: School defines length of program. – If 60 hours required, 90 attempted allowed – If 120 hours required, 180 attempted allowed Must be measured at each evaluation point Student is ineligible at the evaluation point where indicated will exceed max timeframe NOT at the point when they actually reach the max timeframe.

18. SAP Measurements Quantitative Standard: Pace: Students must progress through their program to ensure that they will graduate within the maximum timeframe Must be Cumulative (can also have pay period requirements) Pace Calculation: – Total Earned Hours / Total Hours Attempted – Common standard: 66.67% (120/180= 66.67%) – Rounding is optional for Pace (use standard rules) But must be consistent

19. SAP Measurements Quantitative Standard: What’s “Earned”? (aka Successfully Completed) – When a passing grade is posted (D or better, or a Pass –if Pass/Fail) What’s “Attempted”? – When a passing or non-passing grade is posted (A, B, C, D, F, Passed, Failed, Incomplete, Withdrawn) What’s “Not attempted” and “Not Earned”? – dropped without a grade, not on transcript – Usually dropped during “Drop/Add” timeframe – Remedial Classes (if you opt not to include them)

20. SAP Measurements Quantitative Standard: Example 67% Pace (8 years) Year Year Att. Hrs. Year Ern. Hrs.Year % Pace Total Att. Hrs. Total Ern. Hrs.% Pace 1241666.67%241666.67% 2241666.67%483266.67% 3241666.67%724866.67% 4241666.67%966466.67% 5241666.67%1208066.67% 6241666.67%1449666.67% 7241666.67%16811266.67% 812866.67%18012066.67%

21. SAP Measurements Quantitative Standard: Example 84% Pace (6 years) Year Year Att. Hrs. Year Ern. Hrs.Year % Pace Total Att. Hrs. Total Ern. Hrs.% Pace 1242083.33%242083.33% 2242083.33%484083.33% 3242083.33%726083.33% 4242083.33%968083.33% 5242083.33%12010083.33% 6242083.33%14412083.33%

22. SAP Measurements Graduated Pace You can scale your % Completion rate, – IE: 50% 1 st year, 75% 4 th year, 84% 6 th year – but… Must document that a student with < 67%. could still meet the standards required for graduation complete degree within the Maximum Time Frame still meet Qualitative Standard (GPA) Who this helps: Students who have to withdraw (ie medical reasons) Students who fail major courses 1 st year, and change majors

23. SAP Measurements Quantitative Standard: Example Graduated (8 years) Year Year Att. Hrs. Year Ern. Hrs. Year % Pace Total Att. Hrs. Total Ern. Hrs.% Pace 1241250.00%241250.00% 2241250.00%482450.00% 3241666.67%724055.56% 4241666.67%965658.33% 5241666.67%1207260.00% 6241875.00%1449062.50% 7241875.00%16810864.29% 812 100.00%18012066.67%

24. SAP Measurements Quantitative Standard: Example Graduated (6 years) Year Year Att. Hrs. Year Ern. Hrs. Year % Pace Total Att. Hrs. Total Ern. Hrs.% Pace 1241250.00%241250.00% 2241875.00%483062.50% 3242083.33%725069.44% 4242291.67%967275.00% 524 100.00%1209680.00% 624 100.00%14412083.33%

25. Special Courses Your policy must explain how you deal with these courses – Incompletes – Withdrawals – Repeated Courses – Transfer Credits Can’t exclude courses with grades of “W” Must include all courses attempted.

26. Special Courses Incompletes: – Best Practice: Treat the same way your campus treats them for GPA purposes – Do they affect % Pace ? – Do they affect GPA? Withdrawals: – You can’t exclude courses with grades of “W” – They usually affect % Pace but not GPA Repeated Courses: – Is the first occurrence removed from transcript? – Must still use the grades for both times taken towards GPA Remedial Courses: – Must count for Qualitative Measure – Not required to be counted for Quantitative Measure

27. Special Courses Transfer Credit Hours – If accepted for credit towards degree program: Your policy must count them as attempted hours Your policy must count them as earned hours Your policy must specify: – IF grades of “I” or “W” are attempted, if the course COULD have counted; – IF grades of “F” are attempted, if they aren’t accepted for transfer but COULD have counted; – IF grades of “D” are attempted/earned, if they aren’t accepted for transfer but COULD have counted; – IF a student begins enrollment but his transcript is not fully evaluated, how you will treat them. You can OPT to include transfer hours NOT accepted toward the degree program

28. Special Courses Changing Majors: – Your Policy May Specify how a change in major affects credits Exclude courses that no longer count towards the new major. Limit how many times a change of major can “reset” the student’s academic progress – Best Practice: Require courses from prior major to fill as many electives as possible for new major. – Remember: Students are still limited by Pell Limits (600%) Loan Limits (Aggregates and 150% Subsidized Limit) Unusual Enrollment Patterns

29. Appeals Schools are not required to accept appeals If school does accept appeals, policy must: – Specify if a student can appeal – How a student appeals – When a student can appeal (deadlines) – How many appeals are allowed (if limited) – Documentation expected for appeals

30. Appeals SAP Appeals Must… – State that this is an appeal to regain FSA eligibility (usually specified on a signed form). – State the reason the student didn’t meet SAP – State what has changed that will allow the student to be successful going forwards – Include an academic plan that shows either: Student will meet SAP by next review period, or Student will regain FSA eligibility before Max Timeframe; or Courses student needs to complete the degree and when the student will take those courses.

31. Appeals Basis for Appeals as stated by DOE: – his injury or illness, – the death of a relative, – or other special circumstances. What must student’s appeal state? – What extenuating circumstance affected their ability to do well during the period of academic difficulties; – What actions has the student taken to resolve the issue; – What else has changed since then to prevent the issue from occurring again. Cannot be “Poor Judgment” or “Lack of Maturity”. Shouldn’t be “I failed because the classes were hard”. Should be a factor reasonably beyond their control.

32. Appeals What documentation do you require? – Personal Illness: Medical documentation Letters from doctors Medical excuses from doctors for time missed Must show dates of service Must show medical issues Students may have to sign releases for HIPA to get the documentation. Students may have to pay for copies of records. – Death in Family: If not immediate family, must explain relationship in detail Copy of Death Certificate Obituary Newspaper articles

33. Appeals Special Circumstances – What’s an approvable Special Circumstance? Was this beyond the student’s reasonable control? Could this reasonably impact the student’s academic success? Is it sufficient to justify the grades the student earned? Is it sufficiently documented? – Are you consistent in your practices? You can evaluate each appeal on its own merits and still be consistent; Best-Practice: Make a list of specific special circumstances you have approved before and documentation you require;

34. Appeals Special Circumstances Examples… Change in Work Schedule A letter from employer stating they did change the student’s work schedule and that they would not adjust for the student’s school schedule at that time. A letter from student explaining why the student needed to stay employed during these enrollment periods. Evidence that it will not be an issue again. Transportation Issues: A letter stating that the student had a transportation plan before classes started, what changed and when, and what now has resolved the issue. Documentation of new transportation (ie Vehicle Registrations, etc…). Traumatic or Extraordinary event: Documentation of the event with a full explanation of how it affected the student at that time and what now has changed to resolve the issues.

35. Probationary Semesters “Financial aid probation—A status a school assigns to a student who is failing to make satisfactory academic progress and who successfully appeals. Eligibility for aid may be reinstated for one payment period.” Should you grant “Probation?” Can you answer “Yes” to these questions? – Can GPA return to the standard in 1 semester? – Can % Pace return to the standard in 1 semester? – Will the student still be able to complete all graduation requirements before the maximum time frame? If not, you may be setting the student up for failure. An Academic Plan is usually a more reasonable approach.

36. Academic Plans Used when it will reasonably take more than 1 payment period for a student to regain FSA eligibility. Academic Plans have three components: – Hours Attempted and Earned each payment period (showing progress towards Pace) – Anticipated GPA -semester and cumulative (showing progress towards GPA required for graduation) – Graduation Plan: Courses required to complete degree (if student will clearly go over maximum time frame). Student will have a new Review Period schedule (usually each payment period meets SAP again). Plan must show how SAP will be met by a specific point in time

37. Academic Plans Who makes the plan? – Student – Advisor – FA Counselor – Appeals Committee – A combination Are they properly trained to do so? Do you need a SAP Academic Plan worksheet?

38. Academic Plans YOUR CURRENT ACADEMIC STANDING # of Years in Degree? (BOL/BLS is 4, ADN is 3) See SGASTDN for "College/Degree" SAP ISSUE? Inst. Attempted Hrs See SHATERM for remaining fields Transfer Attempted Hrs Overall Attempted Hrs0 Max:90 Inst. Earned Hrs Transfer Earned Hrs Overall Earned Hrs0 Goal:60 Inst. GPA Hours Inst. Quality Points Additional GPs From "grade frogiveness" not applied yet Inst. GPA#DIV/0! Min: 2.00#DIV/0! % Completed#DIV/0! Min.67%#DIV/0! ACADEMIC PLAN Your total earn hours goal is60 SEMESTER Hours Plan to Attempt Hours "W" Hours Plan to Earn Est. Term GPA Grade Forgiv. GPs New CGPA (GP/GH) % Com- pleted MEETS SAP? New Grade Points New Grade Hours New SAP Attempted Hours New SAP Earned Hours #DIV/0! 0000 0000 0000 0000 0000 Remaining60 2.000 100.00%YES12060 Exceeds Max Att Hrs by: The normal maximum attempted hours is90

39. Academic Plans Hours Attempted and Earned: – If student can’t complete degree before 150% max, then should be 100% for each semester – If student can complete degree before 150%, you can allow % completion rate to be lower. – Best Practices: Set to lowest % Pace rate necessary Set the highest % Pace rate in place in earliest semester, so student has to prove ability Limit # of attempted hours if student doesn’t show ability to complete full-time work (ie: excessive “W”s)

40. Academic Plans Anticipated GPA – Calculate the minimum GPA necessary for enrollment – Should attain GPA for Graduation before Max timeframe. – If not possible, at least by graduation date – Set minimum GPAs per payment period – Hold student to Cumulative GPA required for graduation, and to % Pace. – Sometimes a student might have a different semester GPA than you expected, but still meet the Cumulative. – Grade Forgiveness/Amnesty/Replacement, etc… These can help the GPA required for Graduation Can be an aspect of the Academic Plan

41. Academic Plans Know your Math – How is GPA calculated on your campus? – Are any courses weighted differently? – Does grade forgiveness/replacement/amnesty apply? If so, how will it affect both measurements? – Does the student anticipate dropping a course? – Will the student need to exceed the Max Timeframe? – Is it mathematically possible for the student to regain eligibility?

42. Academic Plans Inst. Attempted Hrs24 Transfer Attempted Hrs0 Overall Attempted Hrs24 Inst. Earned Hrs12 Transfer Earned Hrs0 Overall Earned Hrs12 Inst. GPA Hours24 Inst. Quality Points36 Additional GPs Inst. GPA1.500 % Completed50.00%

43. Academic Plans SEMESTER Hours Plan to Attempt Hour s "W" Hours Plan to Earn Est. Term GPA Grade Forgiv. GPs New CGP A (GP/ GH) % Com- pleted MEET S SAP? New Grade Points New Grade Hours New SAP Attempte d Hours New SAP Earne d Hours Fall 201512 2.500 1.83366.67%NO6636 24 Spring 201512 2.500 2.00075.00%YES9648 36

44. Academic Plans Graduation Plans: – If student can’t complete degree before 150% – Should give a list of courses required to complete the degree – Should include a semester-by-semester plan for these courses – Should have advisor’s signature – Should follow the plan closely – May need to change the plan: update appeal.

45. Academic Plans

46. Review Period Schedule: – Doesn’t follow normal SAP schedule – Student is on a Probation Semester first – Should recheck courses after drop/add. – Check academics after Prob. Semester – Should check each semester of appeal plan – Could check annually after Probationary Semester – Must be meeting plan or not elig for FSA. – Once meets SAP standards, returns to regular Review Period Schedule (ie Annually).

47. Academic Plans Know your Student – Is it reasonable to expect these academic requirements out of this student (Based on academic history)? – Should you limit the student’s enrollment status, require a change of major or set other such limits? – Are you only increasing the debt burden of the student? – Is this a wise investment of Federal, State and Institutional Funds?

48. Other Questions you should ask: How long should an academic plan last? – One semester? One Year? Two Years? – My office usually limits a student to 4 semesters – How long past the 150% timeframe is OK? – My office usually limits a student to 175% (210 hours). – How long will the student retain financial aid eligibility? Pell limited to 6 Full-time years Loans limited by aggregates Most other aid limited to 4 full-time years – Can the student complete the degree without aid? If so, should the student to pay for one or two semesters first?

49. Other Questions you should ask: What GPA is too low to reasonably recover? Current Attempted Hours Current Earned Hours Current GPA Required Hours (Attempt & Earn) Required GPA for these hours 24181.875242.125 24151.75482.125 24121.50482.25 24121.00482.50 2460.50482.75 2400.00483.00

50. Other Questions you should ask: Should the student be evaluated mid-semester? – Pros: You could stop future disbursements (if any) You could stop future awarding (if won’t meet SAP) You could add additional requirements – Academic Counseling – Tutoring You may become aware of unofficial withdrawals – Cons: Requires a large allocation of time You must act on the information you discover Professors may not have sufficient grades for estimates You can’t redact funds already disbursed Reduces student responsibility (you’re not their parent)

51. Other Questions you should ask: Does a “one-size-fits-all” Plan work? – Yes, if… Used for those within a set GPA/PACE range Wouldn’t cause student to exceed other limits Would be reasonable for all students Would allow all students to still graduate by meeting these standards. Allows case-by-case adjustments as necessary

52. One-Size-Fits-All Plans Pass all attempted hours 2.50+ GPA average per term Until meets SAP, to a limit of 48 hours. Wouldn’t fit: < 1.00 GPA after 24 attempted hours < 1.50 GPA after 48 attempted hours < 48 hours from SAP Limit of attempted hours (162 if limit is 210) Current Attempted Hours Current Earned Hours Current GPARequired Hours (Attempt & Earn) Required GPA for these hours 24181.875482.50 24151.75482.50 24121.50482.50 24121.00482.50

53. Other Questions you should ask: Who should be the primary advisor? – Academic advisor? We require Academic Advisors to sign the Appeal form Our Academic Advisors complete Graduation Plans – Financial Aid Counselor? We advise the student to have the appeal reviewed by a FA Counselor The FA Counselor can help the student create the Academic Plan Should a student be able to adjust his plan? Does a one-size-fits all Plan work?

54. Other Questions you should ask: Should a student be able to adjust his plan? – It is allowed by regulations – Student must write an appeal statement explaining why the adjustment is necessary – The appeal adjustment must be approved – What are acceptable reasons? Unable to continue at full-time enrollment Courses not offered Change in major Mis-advised Does a one-size-fits all Plan work?

55. Appeals Committees SAP Appeals Committees: – How many people review the appeals? – Do all members receive a copy of your policy? – Do they understand it? – Who is represented? (Faculty, Staff, what offices?) – Are all members aware of FERPA? – Who makes the decision? – Can students “appeal” the “decision”? – Is all of this specified in your policy?

56. Appeal Decisions Appeal Approvals and Denials – You should notify the student of the decision – You should specify who notifies the student – You should have decisions come from the SAP Appeals Review Committee (rather than a specific person) – You should indicate if the student is approved for a Probationary Semester or an Academic Plan – You should include any additional requirements – You should require the student to sign the Academic Plan.

57. Reestablishing Eligibility Your policy must… – explain how to reestablish eligibility – explain Appeals with Probation or Plans – explain that periods of non-enrollment do not reestablish eligibility – explain that periods of enrollment without financial aid do not (on their own) reestablish eligibility. Note: you can require through an Academic Plan that a student sit out for a period of time but that alone cannot be sufficient reason to appeal (must still have a valid reason for appeal).

58. Students with Intellectual Disabilities “Students with an intellecual disability (see margin note) can receive funds from the Pell Grant, FSEOG, and FWS programs. They must be enrolled or accepted for enrollment in a comprehensive transition and postsecondary program (as defined in 34 CFR 668.231) for students with intellectual disabilities and must maintain satisfactory academic progress as determined by the school for this program. HEA Sec. 484(s)” FSA Handbook 13-14 Vol 1 – P 1-5 34 CFR 668.230–233 20 U.S.C. 1091, 1140

59. Evaluate How to evaluate your Academic Plans – Keep a list of student’s who appealed – Keep a record of those approved – Keep a record of who did or didn’t meet their plan – Evaluate three items: Original GPA and PACE Min GPA and PACE required in Plan How many payment periods passed – Should you be setting a higher minimum for an appeal to be approved? – Should you be lowering the Plan standards?

60. Evaluate Example: – You had 100 appeals – You approved 50 – Of those, 25 met the conditions of appeals – What changes could you make? GPA Range# Appeals Approved# Met Plan# Failed Plan <1.01019 => 1.0 and <1.520515 =>1.5 and <1.75541 =>1.75 and <2.00550 =>2.00 (Pace only)10 0

61. Evaluate Some Questions to ask when evaluating: – Should we lower SAP minimum standards to prevent some students from having to appeal? – Should we increase the minimum GPA for which we will approve an appeal, to prevent some students from receiving aid wastefully? – Are our academic plans too strict? – Are we setting a student up for failure? – Are our academic plans to easy? – Are we giving aid away to students who won’t be able to make the grade in the long run?

62. Evaluate When to Evaluate? – Every other year, or even less often – You need multiple years of data – After you have evaluated plans from prior year – Before approving plans for next academic period – Sooner if you the data is obvious How to test? – For next year, track students who you might include/exclude on your proposed changes – Implement changes the year after that – Sooner if the data is obvious

63. SAP Compliance Issues Consistently in the top 10 Compliance/Audit findings – “Failure to develop a policy that meets minimum Title IV requirements” – “Misalignment of pace of progression and maximum timeframe” – “Applying a different policy than the official written SAP policy” – “Failure to comply with the Program Integrity regulations, effective 7/1/2011” – “Failure to properly monitor and/or document satisfactory progress”

64. Feel Free to Contact Me Kenneth T. Cole Director of Financial Aid and Veteran Benefits USC Lancaster PO Box 889 Lancaster, SC 29721-0889 colekt@mailbox.sc.edu 803-313-7069