Satisfactory Academic Progress The Regulations and Implementation at Berkeley College Howard Leslie – Vice President, Financial Bryan Hoppe – SAP Coordinator

Schools must have reasonable standards for measuring a student’s satisfactory academic progress toward the degree or certificate  A reasonable standard is in accordance with updated (PROGRAM INTEGRITY 2010 – EFFECTIVE 2011) regulatory section  Consistent application to all students within categories of students  Monitored at least annually  Description of effects of course incompletes, withdrawals, repeated courses and transfer in credits  Have a stated Maximum time frame Satisfactory Academic Progress

 Specific GPA requirement (Qualitative)  Pace requirement (Quantitative)  Treatment of transfer credits  Treatment for Remedial and ESL  Financial aid warning definition*  Financial aid probation definition*  Academic Plan definition*  Appeal Process SAP Policy Must Include

* Must schools adopt the terminology, such as warning and probation, used in the regulations? Yes. The preamble to the October 29, 2011 final regulations (75 FR 66884) states that institutions must incorporate these regulatory changes into the information they provide to students; this includes ensuring that the information made available by the institution uses the terminology used in the regulations. Therefore, to the extent that your institution uses the statuses we describe in the new regulations, it must use the terminology in the regulations.

Options:  For programs of study that are one academic year or less in length, school must evaluate SAP at end of each payment period.  For programs of study longer than one academic year School must evaluate at least annually to correspond with end of a payment period but a School may evaluate at end of each payment period.  If annual option is selected there is a sacrifice – stay tuned. How Often is SAP Evaluated?

 Each official evaluation must include evaluation of GPA and pace  Evaluations must be at end of payment period no matter how often progress is monitored  Clock hour schools – see Electronic Announcement June 6, SAPReviewforStudentsinClockHrs.html SAP Evaluations

 SAP policy must describe how student’s GPA and pace of completion are affected by:  Incompletes  Withdrawals  Repetitions  School’s policy for Transfer of credit from other institutions (Accepted transfer credits count as both attempted and completed hours ) SAP Policy Requirements (continued)

 Specify GPA required at each evaluation point  If GPA not appropriate, standard must be a comparable assessment measured against a norm  For programs longer than two academic years, “C” average or equivalent required at end of second year, or academic standing consistent with the institution’s requirements for graduation  Key consideration: Will GPA be at graduation requirement before student reaches Max Time-frame? GPA Requirement

 Quantitative component:  Policy specifies the pace at which a student must complete in order to complete within maximum time to complete  School must evaluate Cumulative hours completed and Cumulative hours attempted  Schools are to make public the length of their programs (Part of Consumer disclosures) Pace Requirement

 For undergraduate programs, must be no longer than 150% of published length of educational program  For credit hour programs, as measured in credit hours attempted  For clock hour programs, as measured in cumulative clock hours required to complete and expressed in calendar time  For gradate programs of study, school defines the maximum based upon length of program Maximum Time Frame

BA requires 120 credits for graduation Maximum Time Frame = 150% X 120 = 180 credits Pace calculation : 120/180 = 67% (also 100/150 = 67%) Student earning 67% of credits attempted is on pace to complete the program within the maximum time frame. Applicable at any enrollment status Credit Hour Example

Program is 1,200 clock hours Students attend 30 hours per week Program scheduled to last 40 weeks 40 X 150% = 60 weeks maximum time frame A student must complete 20 hours per week in order to complete 1,200 hours in 60 weeks Clock Hour Example

 Status only available to students at schools that monitor progress at the end of each payment period  Student may receive Title IV aid for one additional payment period  Status may be assigned without student action or appeal  Status is optional Financial Aid Warning

 Student meets SAP standards and is off warning  Student does not meet SAP standards:  Student successfully appeals and is placed on probation or an academic plan or  Student does not appeal, or appeal is denied and school explains how student can regain eligibility After Financial Aid Warning

 Financial Aid Warning status not available  Probation requirements same as schools that evaluate at each payment period  Student not making progress is not eligible for further Title IV assistance, unless student successfully appeals Annual Evaluations

 Process by which a student who is not meeting SAP standards appeals for reconsideration of eligibility for Title IV aid Policy must describe conditions under which a student may file an appeal  Appeal must include information from student explaining why the student failed to make SAP and what has changed that will allow the student to make SAP at next evaluation point  Appeal process is optional SAP Appeal

 School determines that student will be able to make SAP standards by end of next payment period OR  Student is placed on an academic plan that will ensure the student is able to meet SAP standards by a specific point in time SAP Appeal Approval

 Status available for a student not making progress who has appealed and had aid eligibility reinstated  Student may receive aid for one additional payment period  School may require student action while on probation  Possible use of academic plan Financial Aid Probation

 Student meets SAP standards and regains aid eligibility  Student does not meet standards :  Student successfully appeals and is placed on an academic plan Or  Student does not appeal, or appeal is denied and school explains how student can regain eligibility After Financial Aid Probation

 Alternative to probation – available to all schools  A plan that, if followed by the student, specifies a point in time at which the student will be able to meet the institution’s SAP standards  Student on plan is evaluated against the plan requirements, not regular SAP standards  Plan should ensure student completes within maximum timeframe of program or have procedures of how this will be evaluated and time extended Academic Plan

 Institution must notify student of results of SAP review that impacts the student’s eligibility for Title IV aid  If institution has appeal process, must describe the specific elements required to appeal SAP  May specify how often and how many appeals are allowed  If no appeal process, description of how student may re-establish eligibility for future Title IV aid must be specified SAP Notifications

Do you have fixed or graduated standards? How will you treat course incompletes, withdrawals and repetitions? How will you treat transfer credits? How will you treat remedial courses? How will you treat changes of major or program? Will these be limited? Ask Yourself Will your policy permit appeals? If so, how many? Who will review appeals? Will your policy permit academic plans? Who will develop academic plans? Approve? Monitor? Very Important: Do you have your SAP policies published and “easily” available for student review?

Appeal—A process by which a student who is not meeting SAP standards petitions the school for reconsideration of his eligibility for FSA funds. Optional process. conditions may include a academic plan for success. 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. Satisfactory Progress Definitions

Financial aid warning—A status a school assigns to a student who is failing to make satisfactory academic progress. The school reinstates eligibility for aid for one payment period and may do so without a student appeal. This status may only be used by schools that check SAP at the end of each payment period and only for students who were making SAP in the prior payment period. Financial aid suspension – student failed to meet minimum standard and was on a FA warning status and/or reached maximum time frame for Program of Study Satisfactory Progress Definitions

Maximum timeframe— For an undergraduate program measured in credit hours, a period no longer than 150 percent of the published length of the program. For an undergraduate program measured in clock hours, a period no longer than 150 percent of the published length of the program as measured by the cumulative number of clock hours the student is required to complete and expressed in calendar time. (Note that a student in a clock hour program cannot receive aid for hours beyond those in the program; the maximum timeframe applies to the amount of calendar time the student takes to complete those hours.) For a graduate program, a period the school defines as time limit Satisfactory Progress Definitions

IMPLEMENTATION AT BERKELEY COLLEGE

Basics Collaboration with Academic Advisement SAP Policy and Academic Policy are equivalent to ensure consistent message to students Although some individual programs have stronger standards such as minimum grade requirements Reviewed after every Term Not approached as punitive, rather as an effective tool to identify at-risk students Focused on providing resources to improve struggling students

Qualitative SAP Standards. Undergraduate Programs Associates Degrees Attempted Credits Required GPA or more2.00 Bachelors Degrees Attempted Credits Required GPA or more 2.00 Certificate Programs Required GPA2.00

Quantitative SAP Standards Undergraduate Programs Degree Programs Attempted CreditsNecessary % Passed or more67 Certificate Programs Attempted Credits Necessary % Passed or more67

Flow of SAP Statuses Fall below standa rd WARN MEE T Appeal Probatio n MEE T Appeal Academi c Plan MEE T NET4

Graduate Program SAP Standards Quantitative Standard Attempted CreditsNecessary % Passed % % 28 or more67% Qualitative Standard Attempted Credits Required GPA or more3.0

Why Academic Advisement? Academic Advisors handle the discussions with students on academic progress instead of Financial Aid staff. This ensures that students that are most in need of advisement receive it. A well designed PeopleSoft system ensures that both Financial Aid and Academic Advisement have all of the resources they need to properly hold students to standards while helping them overcome obstacles to their success.

Focus on Providing Assistance Instead of relying on the threat of loss of funding as a motivator, Advisors aim to identify the source of the student’s struggles and offer resources to overcome them, such as: Tutoring through the Academic Support Center Counseling Services Scheduling issues and Academic Load considerations Discussions of Academic Programs and finding the “right fit” Each student faces different challenges, and identifying these are in both the student and organization’s best interests

Advisor input regarding appeals SAP appeals are reviewed by a committee ensuring consistency across all 10 campuses, but input from advisors is included Student’s appeals are reviewed by their advisor before being sent to committee As the direct student contact Advisors often provide insight into the student’s situation much deeper than the committee would have otherwise Decisions are NOT made by advisors, but their recommendations and comments are included for committee review along with the student’s appeal

1 Student files an appeal 2 Advisor at local campus adds recommendation 3 Appeal is sent to central committee for review 4 Decision on appeal is reached, student is informed and appropriate indicators are issued in PeopleSoft

Service Indicators Force Discussion Holds placed on students’ accounts prevent them from scheduling themselves for courses, which forces a conversation with Academic Advisement. Guarantees that every SAP student is given the opportunity to fully understand their status Person-to-person is much more effective than the required letters alone. Graduated standards means that as attempted credits increase the standards increase as well, so students need to understand not only what standard they fell below but also the standard they will be held to following their next quarter Students on Warning are often the population with the greatest impact potential

Warning students as the front line Checking SAP after each payment period allows the use of a Warning status, which we have found is a very helpful step Students are able to continue into a Warning quarter without appealing, but are forced by an indicator to speak with advisement before creating any future schedules Students on Warning are often the easiest to resolve because they’ve only fallen below standards a single quarter Mathematically they are the easiest to resolve, so if the issues contributing to poor performance can be dealt with early they have great potential to improve quickly

Following Warning quarter Students that improve and are meeting SAP Those still below standards must appeal (and placed on Probation if approved) Some worsened their situation, should be dismissed Some stayed stagnant, would need compelling explanation to be allowed to continue Advisor’s perspective is helpful to consider for cases on the fence Some improved, but not by enough to be above standard

Academic Plans Students still below SAP following their Probation quarter must appeal again Dismissed when appropriate Placed on Academic Plan if approved Academic Plans can be for multiple quarters, but always set specific benchmarks for the student to reach at the end of the quarter Academic Plan students are reviewed at the end of each quarter, students that violated the terms of their plan are dismissed

Academic Plans, cont. Students that are approved to continue on Plan meet again with Advisor to update plan with specifics based on recent performance. Academic plans can include multiple quarters, but always have specifics expectations for the quarter at hand

Dismissals Dismissed students MUST sit out at least 1 Quarter Dismissed students wishing to return must file an appeal Such appeals need to be compelling If approved, dismissed students are always treated as if this was their second appeal and placed on Academic Plan

Readmitting Students Students that last attended prior to the current SAP standards (adopted in 2012) are held to the highest SAP standard upon reentry (2.0 GPA and 67% E/A) Students below these metrics appeal to return regardless of where their attempted credits would put them on the graduated SAP standards Since the policy is designed to identify at-risk students and not be punitive, this guarantees that students that do need SAP-like attention are not overlooked After a quarter in class they are held to the normal SAP Standards

Standards Remain Consistent Providing compassionate assistance is not the same as being lenient Students are provided resources to improve, but it is their choice to accept the help and move forward Dismissals are not only appropriate in some cases, but compassionate as well

SAP Compliance Concerns 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 properly monitor and/or document satisfactory progress 45 Consistently in the top ten program review findings Consistently in the top ten program review findings

Policy Q & A - Different Policies Q1: Is an institution required to use the same SAP policy for all students? A1: No, the policy must explain the qualitative (grade-based) and quantitative (time-related) standards the institution uses to check SAP; however, an institution is permitted to establish different SAP standards for different programs or categories (e.g., full-time, part-time, undergraduate, and graduate students) which must be applied consistently to students in that category or program. 46

Policy Q & A – Non-Accepted Credits Q2: SAP regulations require credit-hours accepted toward student’s program count as both attempted and completed when calculating pace for SAP. Can an institution’s policy include non-accepted credits as attempted credits for purposes of these calculations? A2: Yes. The treatment of these credits would be up to the institution. The SAP regulations do not address non- accepted credits. May refer to transfer credits or credits earned in other academic programs at your school 47

Policy Q & A - Remedial Q3: How are remedial courses treated for SAP purposes? A3: The institution's SAP policy should describe how remedial courses are treated. An institution may, but is not required to, include remedial coursework in determining pace. However, the school must evaluate remedial coursework under the qualitative factor, though it does not have to be part of the GPA. If not part of the GPA, the school must have some other measurement process to evaluate remedial coursework (passing courses, meeting course requirements, etc.). 48

Policy Q & A – Programs > 2 yrs Q4: How does the qualitative portion of a SAP review relate to the requirement for a student to have a GPA of at least 2.0, or academic standing consistent with the institution’s requirements for graduation? A4: …the Higher Education Act requires a specific qualitative review at the end of the student’s second academic year. In this context, we have interpreted the “second academic year” as the student being at the school for 4 semesters or 6 quarters, regardless of a student’s enrollment status. At that point, the student must have a GPA of at least a 2.0 or its equivalent or have academic standing consistent with the institution’s graduation requirements. 49

Policy Q & A – Academic Plans Q5: What is the status of a student who has completed the probationary payment period and who is continuing to receive aid by meeting the requirements of the student’s academic plan? A5: A student who has been reinstated to eligibility under an academic plan and is making progress under that plan is considered to be an eligible student. May be evaluated at the same time as other TIV recipients or at more frequent periods based on plan 50

Policy Q & A – Academic Plans Q6: Can the academic plan be the same for all students or the same by student categories or must the plan be created individually for each student? A6: According to the regulations, the academic plan is developed by the institution and the student individually. It is possible that a general plan could be used for students in a similar circumstance and then customized, as needed, for each student’s particular circumstance. 51

Policy Q & A – Academic Plans Q7: Must the academic plan be mathematically set to graduate student within 150% timeframe? A7: The academic plan must be designed to ensure that the student is able to meet the institution's satisfactory academic progress standards by a specific point in time. In some cases, this could mean that the maximum timeframe would be extended based on the student's approved appeal. 52

Policy Q & A - Probation Q8: How many times may a student be placed on probation for failing to meet SAP standards? A8: A student may be placed on probation for one payment period per appeal. It is possible that a student could be placed on probation more than once in his or her academic career. 53

Policy Q & A - Amnesty Q9: May an institution’s SAP policy include automatic “academic amnesty” in certain circumstances, such as, after a student has not attended for a certain number of payment periods or years? A9: No. The regulations permit use of the automatic financial aid warning status for institutions that review SAP at each payment period. No other status may be granted automatically. A successful appeal is needed to grant financial aid probation status or to develop an academic plan. 54

Policy Guidance – Academic Plans Q10: The regulations indicate that an academic plan must be designed for a student to meet SAP by a specific point in time. How do we define a future point in time? A10: Where applicable a date should be used. If a date cannot be confirmed then a school should use some kind of defined end-point – after the 3 rd semester, anticipated graduation date, etc. If the graduation point is after the 150% max timeframe, the graduation point should be indicated in some format. It cannot simply be an open- ended process; needs to be a finite point. 55

Policy Guidance – Regaining Eligibility Q11: What happens if a student is on an academic plan and at the of the payment period they are not meeting the plan requirements but are now meeting the general SAP standards? A11: Once a student is meeting the general SAP standards at a checkpoint, regardless of the plan, they are now in good standing (main point of the plan is to help the student meet the SAP standards). A school may want to indicate in a plan that a student can continue receiving TIV aid if they meet the plan criteria or meet all general SAP standards. 56

Policy Guidance – Pass/Fail Courses Q12: Does a school have to factor in Pass/Fail classes, that are part of the student’s program of study, as part of the school’s qualitative measure (GPA)? A12: No, the school does not have to factor in those limited classes a student takes as Pass/Fail into the GPA measurement as long as the course is factored into the quantitative measurement (pace of progression). 57

Resources/References FSA Assessments, Student Eligibility section:  , (SAP)  FSA Handbook Vol. 1, Chapter 1  Electronic Announcement - September 2, 2011  Policy Q & A Webpage on program integrity regulations  /integrity-qa.html /integrity-qa.html  Upper right-hand side of IFAP  Topic – “Satisfactory Academic Progress” 58