I’ve been spending a lot of time reading the latest batch of Final Program Review Determination letters released by ED last month. One thing is for sure, some people still don’t understand Satisfactory Academic Progress, otherwise known as SAP. So, this month I’m writing about SAP. After all, I wouldn’t want you to have problems like these schools did.

Whether it’s deficient policies or schools simply failing to administer their own policies correctly, SAP findings continue to be a top program review finding year after year. According to the Department, each year they’ve issued findings and liabilities to dozens of schools and colleges because of SAP issues. It’s problematic because since SAP is directly connected to students’ aid eligibility. Incorrect determinations of SAP and aid eligibility, whether by policy, or by inadequate monitoring, results in ineligible disbursements. Get busted for ineligible disbursements and you’ll literally pay for it. Liabilities related to SAP in Fiscal Year 2017 ranged from $25,000 on the low end (small proprietary school) to as much as $5.6MM (mid-sized public college).

In 2011, a package of rules known as the Program Integrity Regulations went into effect. The new regulations required schools to develop, publish, and apply reasonable standards for measuring whether a student is maintaining SAP in his or her educational program. These regulations created new minimum standards institutions must use when monitoring Satisfactory Academic Progress including specific qualitative and quantitative requirements which include requirements to define pace or progression and maximum timeframe. ED gives schools flexibility in choosing the frequency of evaluations and even in choosing whether to implement provisions for financial aid warning, probation, and appeals but these topics and others, need to be addressed by your school’s policies.

Unfortunately, some colleges haven’t fully implemented these requirements going on eight years after they took effect. It’s no surprise however that ED ranks “Failure to comply with the Program Integrity Regulations that went into effect on July 1, 2011” as one of the most common SAP findings from recent program reviews.

This finding can stand on its own as a common problem, but, it’s also an overarching finding which encompasses myriad underlying SAP issues. Knowledge is power, so here are some common pitfalls to avoid and some tips for making sure your Satisfactory Academic Progress policies and procedures are compliant.

  1. Failure to develop a policy that meets the minimum Title IV requirements.

The 2011 SAP regs, require institutions to incorporate several new elements into their SAP policy. In addition to specific qualitative and quantitative requirements, requirements to define pace and maximum timeframe, and provisions for financial aid warning, probation, and appeals, an institution’s SAP policy must describe how a student’s GPA and pace of completion are affected by incompletes, withdrawals, course repetitions and transfer credits. If your policy is missing any of these elements, it might not meet the minimum Title IV requirements leading to other administrative capability issues.

The SAP policy at the college that was assessed liabilities of $5.6MM didn’t comply with the 2011 SAP requirements. As a result, the school disbursed Title IV aid to students who had failed to make SAP under ED’s current standards, students who should have been deemed ineligible for further Title IV aid due to failing to make SAP. Not all SAP issues are as egregious or costly though.

  1. Applying a different policy than the official written SAP policy.

Prior to 2011 SAP requirements were less prescriptive and there were fewer limits on aid eligibility for students who failed to make the grade. Back then, SAP, although required for aid eligibility was viewed largely as an academic measurement and thus often the responsibility of a Dean or Department Chair to develop an institution’s academic policy and to monitor student progress. Even at schools that have updated SAP policies, old policies linger in some form and it’s important to make sure you follow your official SAP policy for Title IV purposes.

668.32 states that students are expected to maintain satisfactory academic progress in their course of study according to the institution’s published standards of satisfactory academic progress.

Yes, you have to publish your SAP policy.

Yes, you have to use the one that’s published.

No, your academic policy from 1998 won’t (likely) cut the mustard here.

Now that doesn’t mean that your school can’t have another policy; for instance, something like a policy on academic standing. It’s not uncommon for colleges to have such policies since they largely don’t impact aid eligibility and are typically applied to all students including those students who are not receiving aid. The key here is that your Title IV SAP policy must be at least “as strict or stricter than other school policies”.

Having a SAP policy “as strict or stricter than other school policies” refers to the actual measurements used to monitor qualitative and quantitative standards like GPA and pace of progression. That’s why it’s important to ensure that academic policies if they exist, aren’t confused with your Title IV SAP policies. Make sure you publish your official Title IV SAP policy and follow that one. Also, if your school publishes different SAP policies for different programs or categories, you must be sure to apply the correct policy consistently to students in that category or program.

  1. Misalignment of pace of progression and maximum timeframe.

The 2011 regulations capped financial aid eligibility for undergraduate programs at 150% of the published program length in credit hours. Graduate programs are generally free to define maximum timeframe based on the length of the program. And for clock hour schools, max time frame is expressed in weeks. It’s important that your policy specifies the pace at which students are expected to progress toward program completion. The maximum timeframe is used to determine the pace of completion.

Consider the standard example for aligning pace with maximum timeframe, a four-year degree program which requires 120 credits for completion. 120 x 150% = 180 attempted credits. This is your maximum timeframe. To calculate Pace, divide 120 by 180. 120/180 = 66.67% pace requirement (rounding is permissible, and this is commonly rounded to 67%).

Let’s say for the sake of argument that your institution requires more academic rigor, thus requiring stricter SAP standards than the minimum standards required by ED. That’s okay, but you must still define both pace and maximum time frame and make sure that the two are properly aligned to one another.

As your pace requirement increases above 67%, your maximum timeframe decreases from 150%.

Let’s say that your policy requires students to make 85% pace toward completion, the maximum timeframe must be something less than 150% of your published program length.

To calculate maximum time frame, first divide 100% scheduled length by the required pace.

In this case, 120 credits is the 100% scheduled length for a bachelor’s / 85% pace = 141 credits maximum timeframe.

To test this, reverse your arithmetic and divide 120 Credits by the 141 maximum time frame and you’ll get 85% pace.  120/141 = 85% pace.

Try it with your own pace and max timeframe to see if they are aligned properly. If the math doesn’t work, you may have a problem that needs fixing.

  1. Failure to properly monitor and/or document satisfactory academic progress.

This one shouldn’t need explaining, but this issue is all too common. One school was cited for problematic transcripts which failed to list students’ course work in conjunction with each payment period. That made it extremely difficult to determine if students were making SAP. Although the school did use a SAP evaluation form, the form only included check marks indicating that qualitative and quantitative progress was checked, but the school didn’t provide any substantiating documentation of what students’ progress was, couldn’t correlate it with a transcript or proof that the evaluation was done at the end of the payment period. Although this finding was eventually closed, it highlights the concern. The school was required to revise their SAP policy and provide a  detailed narrative and supporting documentation to ED to prove students’ eligibility. Not fun!

In another program review, ED found that an online college simply wasn’t monitoring SAP and was letting students continue to receive aid despite having failed SAP. The college had no evidence that it ever put students on warning or subject students to loss of aid. It turns out, the college also failed to notify students of changes in aid eligibility. When all was said and done, ED found the college made over $700,000.00 in ineligible disbursements and hit them with a hefty liability.

In another case, ED found that one small school’s SAP policy didn’t require monitoring of its students’ progress at the correct intervals for its clock hour programs. Specifically, the institution’s policy did not monitor SAP at the end of a payment period as required. ED also found that it did not apply the Financial Aid Warning status or the Probationary status correctly because the application of these statuses additionally did not correspond to the end of a payment period.

Instead the institution’s policy assessed SAP at strange intervals of 13.5 weeks, 27 weeks, 40.5 weeks and 54 weeks when it should have monitored SAP based on the midpoint of its academic year and scheduled weeks; at the end of 450 scheduled clock hours and 18 weeks (*the school noted they used scheduled hours for SAP). As a result, the institution was required to do a full SAP file review for the two most recently completed award years, revise and update their policy and repay nearly $27,000 in ineligible disbursements to ED. For a small school, even small liabilities can break the bank. And that was just for their SAP problems…

Don’t make the same mistakes and missteps as these schools did. Do and you’re asking for trouble. Regardless of whether your school hasn’t had a program review in 20 years, or you’re PPA is up for recertification soon, take some time to look at your SAP policy and related procedures to ensure they make the grade.

Institutions with questions about Title IV and compliance with Federal Regulations related to Federal Student AId Programs are welcome to contact our office for assistance.