1. Satisfactory Academic Progress Managing the Components & Monitoring Compliance

2. We will cover: Minimum Federal SAP Requirements SAP Policy Requirements SAP Appeals

3. SAP Remains a Top 10 Audit Finding Failure to have an adequately developed policy Failure to consistently or adequately apply SAP policy SAP policy not meeting the minimum Title IV requirements Failure to monitor or document SAP Regulations: 34 C.F.R. §§668.16; 668.32(f);668.34

4. Federal Requirements

5. SAP Federal Requirements Must be Reasonable and Consistently applied Applies to ALL Title IV programs: if a student is not meeting SAP then not eligible for any TIV program Schools have flexibility in developing SAP policy as long as the measurements are “as strict or stricter” than that of non-financial aid recipients in the same program

6. Federal Requirements (cont.) Frequency of Review At least once per payment period for programs equal to or less than one academic year in length At least once per year for students in programs lasting more than 1 year Schools who choose to evaluate more frequently must also include summer terms in their evaluation if the student attends

7. Federal Requirements (cont.) Frequency of Review: Evaluations by Payment Period Good Standing: Student is in compliance with ALL standards Financial Aid Warning (optional): Student is below standards but allowed ONE payment period to return to standards OR Student is ineligible (optional) and Appeal (optional) approval required to resume on aid

8. Federal Requirements (cont.) Qualitative requirement May use an escalating scale that is consistent with graduation requirements For programs of more than two academic years, students must have a cumulative GPA of “C” or its equivalent by the end of their second year of enrollment Number of Semesters Attended Number of Credits Earned Minimum Cumulative GPA Required 0-4 semesters and  1 through 30 credits1.60 0-4 semesters and  31 through 60 credits1.80 0-4 semesters and  61+ credits2.00 5 semesters or more and  All grade levels with any number of credits 2.00 Any semesterGraduate Student3.00

9. Maximum Timeframe Limits of Maximum Timeframe For undergraduate programs, must be no longer than 150% of published length of educational program For graduate programs of study, school defines the maximum based upon length of program Example: Degree program requires 120 credits for completion 120 x 150% = 180 attempted credits is maximum timeframe Federal Requirements (cont.) Quantitative measure (tied to max timeframe) 120 credits / 180 credits = 66.6% (usually rounded to 67%) Student must earn 67% of credit-hours attempted

10. Federal Requirements (cont.) Quantitative Requirements The quantitative standard (pace) that is set for a student to progress through his or her program must be in alignment with the maximum timeframe the student has to complete the program i.e. based on the school’s minimum pace of completion requirements it must be mathematically possible for students to complete a 4 year program within 6 years. School determines pace of completion requirements for graduate students

11. SAP Policy

12. SAP Policy Requirements Policy must include a description of the school’s requirements on each of the following components: Qualitative measurement: minimum GPA requirements Quantitative measurement: pace of completion, maximum timeframe, remedial/repeat coursework How a student may regain their Title IV eligibility once it is lost (i.e. via appeal or other means)

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

14. SAP Policy Requirements (cont.) If used, the school must define and describe the following SAP components (using federal terminology): Warning Probation Appeals Academic plan Financial aid suspension/ineligibility

15. SAP Notifications

16. 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 If no appeal process, description of how student may re-establish eligibility for future Title IV aid must be specified

17. SAP Appeals

18. SAP Appeal (minimum requirements) Appeal must include information from student explaining why the student failed to make SAP Must demonstrate that circumstances have changed and/or barriers affecting satisfactory performance have been removed Before approving appeal, school must also be satisfied that student does have the possible to regain SAP standards within program completion

19. Probation: Available to all schools For students who are not making progress but have successfully appealed Aid is reinstated for ONE payment period Academic Plan: Available to all schools May be used instead of or along with Probation Specifies a point in time at which the student will be able to meet SAP. Can possibly last for the duration of the student’s program Student is evaluated against the plan requirements not regular SAP standards SAP Appeal: Probation & Academic Plans

20. SAP Appeal Denials Theoretically more closely reviewed by Feds than Appeal Approvals Insufficient Documentation or No Mitigating Circumstances Unrealistic academic plans

21. SAP Appeal Best Practices Frequency of Appeal Reviews (per academic year)? Appeal of SAP Decision? Maximum number of Appeals? No Appeals? Include other departments/non- financial aid administrators in the process?

22. SAP Resources

23. Additional Resources 2015-16 FSA Handbook Vol. 1, Chapter 1 NASFAA ASKREGS Knowledgebase Program Integrity Q&A – SAP, http://www2.ed.gov/policy/highered/reg/hearulemaking/200 9/sap.htm

24. Questions Thank you! Nicole McDaniel-Smith & Laura Leslie Wilmington University, Delaware