Verification and Satisfactory Academic Progress Jamie Malone Marty Guthrie U.S. Department of Education

Today’s Agenda Resources Verification Regulations Federal Register Notice Satisfactory Academic Progress Dear Colleague Letter Questions? 2

Resources For information, consult: Notice of Proposed Rulemaking (NPRM), published 6/18/10 –Describes all changes to current reg Final Rule, published 10/29/10 –Responds to comments and describes changes to NPRM –Not a comprehensive review of all reg changes 3

Verification Regulations 4

Verification Effective date delayed until July 1, 2012 – award year Institutions may need time to make changes to their institutional processing systems 5

Verification: General Changes Emphasizes updating requirements through change to subpart heading Removes references to individual programs Defines “subsidized student financial assistance programs” and “unsubsidized student financial assistance programs” 6

Verification: General Changes Subsidized— –Eligibility uses EFC –Verification applies –Pell Grant, FSEOG, FWS, Perkins, Direct Subsidized Loan Unsubsidized— –Eligibility does not use EFC –Verification does not apply –TEACH Grant, Iraq & Afghanistan Service Grant, Direct Unsubsidized Loan, Direct PLUS Loan 7

Verification: General Changes Uses “FAFSA information” instead of “application” Defines “specified year” as base year or year prior to base year –Allows for option of using income data from a different year –No plans to exercise this option at this time 8

Verification: General Changes Must complete verification prior to exercising professional judgment Codifies long-standing policy in regulations 9

Verification: Selection Eliminates 30% limit Department targeting error-prone items to select applications to verify Institutions must verify all applicants we select 10

Verification: Selection Institutions must continue to resolve conflicting information they believe is inaccurate Institutions keep flexibility to select additional information or applications for verification 11

Verification: Exclusions Removes certain exclusions Clarifies provisions applicable to— –Applicants –Parents of dependent applicants –Spouses of independent applicants Lists specific situations when parent’s or spouse’s information is not subject to verification 12

Verification: Updating Applicant required to update all changes in dependency status throughout the award year, except changes resulting from a change in the applicant’s marital status Applicant’s responsibility, not institution’s 13

Verification: Updating FAA may require applicant to update marital status to address inequity or to reflect more accurately the applicant’s ability to pay Documentation not required if the information has not changed during subsequent verification of household size and number in college 14

Verification: Items to Verify Annual Federal Register notice –Items to verify –Documentation Initially, will include the current five data elements 15

Verification: Documentation Specified as acceptable in annual Federal Register notice Retained current documentation requirements with technical changes Added option to retrieve electronic data from IRS 16

Verification: Documentation For applicants with tax filing extension –May require completed tax return when filed –Must re-verify AGI and taxes paid, when/if the tax return is submitted 17

Verification: Documentation Tax return not signed by the tax filer –Must be signed, typed, printed, or stamped by the tax preparer and –Contain the preparer’s SSN, EIN or PTIN 18

Verification: Interim Disbursements Technical and conforming changes May make a disbursement after completing verification but prior to receiving a corrected valid SAR or valid ISIR if the changes would not change the amount of aid 19

Verification: Interim Disbursements To avoid liability, must ensure necessary corrections are submitted to ED Valid SAR or valid ISIR required before disbursement can be made for all Title IV programs 20

Verification: Deadlines Require institutions to follow cash management procedures for Direct Loans Removed the requirement to pay Pell Grant on the higher EFC 21

Verification: Fund Recovery Requires institutions to reimburse program account if disbursement made without receiving corrected valid SAR or ISIR Requires recovery of overpayments that occur from interim disbursements for students employed under the FWS Program 22

Verifications: Corrections Removed $400 tolerance Require all corrections over $25 to be submitted Require all corrections of nondollar items 23

Federal Register Notice 24

Federal Register Notice Published Spring/Summer 2011 Describes verification items Outlines acceptable documentation Lists other verification resources 25

Satisfactory Academic Progress Regulations 26

Satisfactory Academic Progress Previously, SAP requirements and references were included in 3 regulatory sections –Administrative capability §668.16(e) –Student eligibility §668.32(f) –Satisfactory progress § Now all requirements are in § with cross references in §§668.16(e) and (f) 27

SAP: New Regulations New regulations provide— Continued flexibility for institutions to establish their SAP policies Additional flexibility for institutions that monitor SAP more often than annually Definitions for “warning” and “probation” In general, a student who is not making SAP is no longer eligible for Title IV aid 28

SAP: Policy Requirements Specified in § and include— Measurement of student’s progress at each evaluation— –Can take place each payment period, annually, or less often than each payment period –Must occur at the end of a payment period 29

SAP: Policy Requirements GPA that a student must achieve at each evaluation (qualitative standard) Pace of progression at each evaluation (quantitative standard) 30

SAP: Details on Standards Qualitative standard: required GPA –For programs more than 2 academic years: at the end of 2 years, at least a 2.0 or academic standing consistent with requirements for graduation Quantitative standard: pace at which a student must progress to complete within the maximum timeframe –Calculate by dividing cumulative successfully completed hours by cumulative hours attempted 31

SAP: Policy Requirements How student’s GPA and pace are affected by incompletes, withdrawals, repetitions, or transfers of credits Must count transfer hours accepted toward completion of the student’s program as both hours attempted and hours completed 32

SAP: Defined Terms Must incorporate the terminology used in these regulations Must explain terms and use consistently with these regulations Must make sure conditions of each term are clear to students 33

SAP: Defined Terms Defined Term: Financial Aid Warning Status assigned to a student who fails to make SAP at an institution that evaluates SAP at the end of each payment period Student may continue to receive Title IV aid for one payment period No appeal necessary 34

SAP: Defined Terms Defined Term: Financial Aid Probation Status assigned by an institution to a student who fails to make SAP, who has appealed, and has had eligibility for Title IV aid reinstated May impose conditions for student’s continued eligibility to receive Title IV aid 35

SAP: Defined Terms Defined Term: Maximum timeframe For an undergraduate program—basically 150% of the published length of the program For a graduate program—a period defined by the institution that is based on the length of the educational program 36

SAP: Defined Terms Defined Term: Appeal Process by which a student who is not meeting an institution’s SAP policy petitions the institution for reconsideration of the student’s eligibility for Title IV aid 37

SAP: Defined Terms Defined Term: Appeal (more) Must specify the conditions under which a student may appeal including— –Why the student failed to make SAP; and –What has changed that will allow the student to make SAP at the next evaluation 38

SAP: Frequency of Review Regulations are organized by frequency of SAP evaluation— –At the end of each payment period, or –Less frequently 39

SAP: Payment Period Review Evaluating at each payment period: If student fails to make SAP, student— Loses eligibility for Title IV aid May be placed on Financial Aid Warning for one payment period Must make SAP or may be placed on Financial Aid Probation after a successful appeal 40

SAP: Payment Period Review Evaluating SAP each payment period (more) After Financial Aid Probation, student— –Must be making SAP, or –Must be successfully following an academic plan 41

SAP: Academic Plans About academic plans— Not regulated General or specific Flexibility to address student situation Appeal needed to implement or change 42

SAP: Annual Review Evaluating less frequently: If student fails to make SAP, student— Loses eligibility for Title IV aid May be placed on Financial Aid Probation after an appeal After Financial Aid Probation, must be making SAP or successfully following an academic plan 43

SAP: Notifications Notifications Results of SAP review that impact the student’s eligibility for Title IV aid Specific elements required to appeal SAP, if appeal process is used Process for reestablishing eligibility for Title IV aid, if no appeal process is used 44

SAP: Questions People asked about… Using different rates of assessment for different classes of students Evaluating one factor at end of each payment period and another annually Implementing SAP for the 2011 summer crossover payment period 45

SAP Dear Colleague Letter Expected in summer 2011 Will include questions and answers clarifying the SAP provisions in the 10/29/10 regulations 46

47 Contact Information We welcome your feedback. You may contact us at: Phone: Fax: Phone: Fax: