Latest News


A financial aid consultant can help your college identify risks and prevent program review findings

What are the most frequently reported program review findings according to ED?

ED recently released an updated program review guide packed with lot’s of great info to help schools and colleges understand the in’s and out’s of a program review. The new guide covers everything from general program review processes to procedures and guidelines for following up. According to the guide, these are the most frequently cited program review findings. 

These are the top ten most frequently cited program review findings at colleges and universities.

  • Crime Awareness Requirements Not Met
  • Verification Violations
  • Return to Title IV Calculation Errors
  • Student Credit Balance Deficiencies
  • Drug Abuse Prevention Requirements Not Met
  • Student Status – Inaccurate/Untimely Reporting
  • Entrance/Exit Counseling Deficiencies
  • Consumer Information Requirements Not Met
  • SAP Policy Not Adequately Developed and/or Monitored
  • Inaccurate Record keeping

How does your institution assess it’s risk and preparedness for audits and program reviews?

To learn more about how your institution can adjust its processes and reporting to minimize its risk of these federal student aid compliance issues, please contact us.

Get your 2018-2019 IRS Tax Return Transcript Matrix for ISIR Verification here!


ED will release FY 2016 Official Cohort Default Rates (CDR) to all eligible institutions in mid-September. Schools will receive their CDR electronically via their SAIG mailbox.
The Cohort Rates are an important metric used to determine school or program quality. Schools with 3-year CDRs of 30% or greater for three consecutive years or with CDRs greater than 40% for one year may face federal sanctions. Institutions may challenge, appeal, or have their rate adjusted in certain circumstances. Be on the lookout for more information such as an Electronic Announcement announcing the official release dates of the 2016 CDR package from FSA’s Operations Performance Division in the forthcoming days. In the meantime, check out the Default Management Web site which contains resources for Financial Aid Professionals, Data Managers and Students here.


As part of the “Borrower Defense to Repayment Final Rules (dubbed institutional accountability final rules), The U.S. Department of Education amended the Student Assistance General Provisions regulations. New rules were added establishing conditions and events that could have an adverse, material effect on an institution’s financial condition, thus warranting protections for students and taxpayers. These are broken up into two categories; mandatory and discretionary financial responsibility triggering events.

Unlike the Borrower Defense to
Repayment regulations included in this package which will go into effect on
July 1, 2020, the amendments below are scheduled for immediate implementation.

Financial Responsibility – Mandatory and Discretionary Triggering Events

The Final Regulations establish mandatory and
discretionary triggering events that have, or could have, a materially adverse
impact on an institution’s financial condition that warrant financial

The mandatory triggering events are: 

1) Liabilities arising from a settlement,
final judgment from a court, or final determination arising from an
administrative action or proceeding initiated by a Federal or State

2) Withdrawal of owner’s equity from the
institution, unless the withdrawal is a transfer to an entity included in the
affiliated entity group upon whose basis the institution’s composite score was

3) For publicly traded institutions, the
Securities and Exchange Commission issues an order suspending or revoking the
registration of the institution’s securities or suspends trading of the
institution’s securities on any national securities exchange, the national
securities exchange notifies the institution that it is not in compliance with
the exchange’s listing requirements and the institution’s securities are
delisted, or the SEC is not in timely receipt of a required report and did not
issue an extension to file the report; and 

4) For the fiscal year reported, when an
institution is subject to two or more discretionary triggering events, those
events become mandatory triggering events, unless a triggering event is
resolved before any subsequent event(s) occurs.  

Discretionary triggering events in the Final Regulations include:

1) The institution’s accrediting agency issues
an order, such as a show-cause order or similar action, that if not satisfied
could result in the loss of institutional accreditation; 

2) The institution violated a provision or
requirement in a security or loan agreement with a creditor; 

3) The institution’s State licensing or
authorizing agency notified the institution that it has violated a State
licensing or authorizing agency requirement and that the agency intends to
withdraw or terminate the institution’s licensure or authorization, if the
institution does not take the steps necessary to come into compliance; 

4) The institution’s failure to meet the 90/10

5) As calculated by the Secretary, the
institution has high annual dropout rates; and

6) The institution’s two most recent official
cohort default rates are thirty percent or greater, unless the institution
files a challenge, which results in reducing below thirty percent the official
cohort default rate for either of or both of those years or precludes the rates
from either or both years from resulting in a loss of eligibility or
provisional certification.

Finally, the Final Regulations also
update the definitions and terms used to calculate an institution’s composite
score and the composite score methodology to align with changes in FASB
accounting standards. Existing leases will be grandfathered, and the new
regulations only apply to new leases.  Existing
long-term debt rules are also being grandfathered, but the new rules require
tie-ins to plant, property, and equipment new long-term debt.  In addition, the Final Regulations revise
Appendices A and B of the financial responsibility regulations to conform with
the updates and changes in accounting standards.


The United States Department of Education released final regulations for institutional accountability related to Borrower Defense to Repayment loan discharges for Federal Direct Loans. The new regulations revise the standards the Department will use to adjudicate borrower defense to repayment claims and will take effect for all new loans first disbursed on or after July 1, 2020, while preserving the standards for loans that were issued under prior regulations. The Final Regulations preserve three borrower defense periods: 1) Loans first disbursed prior to July 1, 2017, which are subject to pre-2016 regulations; 2) Loans first disbursed on or after July 1, 2017 and before July 1, 2020, which are subject to final regulations published on November 1, 2016, and 3) Loans first disbursed on or after July 1, 2020, which are subject to the 2019 regulations. Under the new regulations, borrowers who are misled and can demonstrate financial harm caused by their institution can file a claim to have their loan discharged. The Department’s new rules give borrowers up to three years from the time they leave school to file a claim. Claims will be reviewed by ED staff using the “preponderance of the evidence” standard. Both borrowers filing claims and institutions that the borrower attended will be required to provide supporting evidence to ED which will determine if a discharge is warranted. In the Final Regulation, the Department defines a “misrepresentation” as: a statement, act, or omission by an eligible school to a borrower that is (a) false, misleading, or deceptive, (b) that was made with knowledge of its false, misleading, or deceptive nature or with a reckless disregard for the truth, and (c) that directly and clearly relates to either 1) enrollment or continuing enrollment at the institution; or 2) the provision of educational services for which the loan was made. According to ED, some examples of misrepresentation include:
  • actual licensure passage rates that are different from those in marketing materials, website, and communications;
  • actual employment rates materially different from those in the institution’s marketing materials, website, and communications;
  • institutional selectivity or rankings, student admission profiles, or institutional rankings that are materially different from those in marketing materials, websites, and communications;
  • the institution does not possess certifications, accreditation, or approvals for programs that it represents that it possesses; representations regarding the educational resources provided;
  • representations regarding the transferability of credits that, in fact, do not transfer to other institutions;
  • representations regarding the employability or specific earnings of graduates without evidence;
  • representations regarding the availability, amount, or nature of financial assistance provided;
  • representations regarding the amount, method, or timing of payment of tuition and fees that is materially different from the amount, method, or timing of actual tuition and fees;
  • representations regarding whether an institution’s courses or programs are endorsed by employment agencies, industry members, government officials, former students, US armed forces, or others without permission; and
  • representations regarding the prerequisites for enrollment in a course or program.
Within these “Institutional Accountability” regulations, the Department also amended several other regulations including regulations for class action waivers, pre-dispute arbitration agreements, and rules for closed-school and false certification discharges. The new regulations will permit institutions to use class-action waivers and arbitration agreements if an institution discloses information about their internal dispute resolution and arbitration processes to students as part of in the borrower’s entrance counseling. The Final Regulations also allow for the borrower to choose whether to apply for a closed school loan discharge or accept a teach-out opportunity. In addition, the closed school discharge window is expanded from 120 days to 180 days prior to the school’s closure. For borrowers claiming a false certification by their school they can also apply and must complete an application.
This information is for informational and educational purposes only. To learn more about how your institution can adjust its processes and reporting to minimize its risk of these federal student aid compliance issues, please contact us.


It’s been almost two years since the Department of Justice’s Antitrust Division began an inquiry into the National Association for College Admission Counseling’s (NACAC) Code of Ethics. The Statement of Principles of Good Practice: Code of Ethics and Professional Practice (SPGP – CEPP) is followed by nearly 8000 NACAC members from colleges and universities. Among enrollment management professionals, the SPGP isn’t just a code of ethics. Instead, it’s a matrix upon which all of admissions operates, and there’s the rub. Is a system that’s arranged with as much pomp and circumstance as college admissions rigged to be anti-competitive? The Department of Justice seems to think so.

Earlier this week, NACAC’s Board of Directors recommended changing course to help the association avoid litigation and trial and to show good-faith and compliance with the DOJ investigation. In a memo to their Assembly leadership and delegates who will be meeting next month, NACAC’s Board and legal counsel recommended that delegates “seriously consider deleting statements within the Code of Ethics and Professional Practices assumed to violate antitrust laws.”

NACAC’s board is recommending that their leadership approve a motion to suspend procedural rules of the Assembly prohibiting amendments to the CEPP, except those recommended by their legal counsel.

Additionally, they’ve proposed a moratorium on enforcing the rules outlined in the of the Code of Ethics and Professional Practices which govern everything from admissions cycle dates, deadlines and procedures to transfer admission and of course early and regular decision. According to NACAC, these are the four main areas that Department of Justice considers to be potentially anti-competitive under anti-trust laws .

Early Decision

NACAC’s guidelines have long prohibited colleges from offering special incentives to students applying or admitted for Early Decision. NACAC proposes removing language that would prohibit colleges from doing so, which in theory will allow colleges to lure students to their campus with offers of preferential housing, better financial aid packages and even special scholarships.

Responsible Practice of College Admission

NACAC member institutions have an agreement that they won’t poach each other’s students. Once a student has committed themselves to a college, institutions simply stop trying to recruit them. This has insulated colleges from competition by members. By striking this language from the CEPP, it seems that colleges may be able to recruit whomever they want , whenever they want, even before or after NACAC’s deadlines.

Admission Cycle Dates, Deadlines and Procedures for First-Time Fall Entry Undergraduates

May 1st is a big day in admissions. That’s when students are expected to commit to a college under regular decision and that’s also when college admission offices have to stop trying to recruit students who have committed to other institutions. NACAC is proposing to remove the language preventing colleges from trying to get students to change their college decision.

Transfer Admission

Under existing NACAC rules, colleges can’t contact applicants or prospective students from prior years unless that contact was initiated by the student themselves. This prevents colleges from recruiting transfer students. If the Assembly indeed votes to remove this provision, colleges will be able to contact students at other colleges and offer incentives for them to transfer.

It’s quite likely that NACAC’s Assembly leadership and delegates will adopt these changes when they meet next month and that means that college admissions is about to change.

Absent the protections provided by NACAC SPGP-CEPP institutions are going to have to work smarter, harder and most of all compete to attract students to their campus. What remains to be seen is whether these changes if adopted will appease the Department of Justice and what repercussions if any will be felt by individual institutions (or even individuals at institutions) who have operated under NACAC’s admissions principals.


In a recent electronic announcement, Federal Student Aid announced that a new report on Financial Literacy Best Practices has been released. The report dubbed Best Practices for Financial Literacy and Education at Institutions of Higher Education is the result U.S. Financial Literacy and Education Commission. According to the Electronic Announcement, the report provides general best practices for financial education programs. Specifically, the report makes recommendations in the following areas:
  • Providing clear, timely and customized information to inform student borrowing;
  • Effectively engaging students in financial literacy and education;
  • Targeting different student populations by use of national, institutional and individual data;
  • Communicating the importance of graduation and major on repayment of student loans; and
  • Preparing students to meet financial obligations upon graduation.
This is useful information for helping student access information to make college affordable.


Registration for the 2019-2020 IPEDS Data Collection Schedule opens in August. Reporting to IPEDS is mandatory thus; all institutions are required to register for the 2019-2020 data collection cycle. UserIDs and passwords for 2019-2020 will be distributed to all institutions on August 7. Those with designated keyholders will receive information via email. All institutions for which there is no designated keyholder will receive a letter directed to the CEO containing registration information. To register, visit the IPEDS website at:

During the Registration Period, institutions are encouraged but not required to complete Report Mapping, Institution Identification, and IC Header. Report Mapping (if applicable) and Institution Identification must be completed, and IC Header must be locked before the Fall surveys can be started. Report Mapping and IC Header are available until the end of the Fall collection. Institution Identification is available through Spring.
On August 28, NCES will review the registration status of each institution. If an institution has not registered as of this date, a letter will be sent to the CEO requesting appointment of a new keyholder.

If you are responsible for reporting IPEDS data at your school, here are some other important dates to mark on your calendar.

  • September 4, 2019 – Fall Collection Opens – Institutional Characteristics; Completions; 12-month Enrollment
  • December 11, 2019 – Winter Collection Opens – Student Financial Aid; Graduation Rates; 200% Graduation Rates; Admissions; Outcome Measures
  • December 11, 2019 – Spring Collection Opens – Fall Enrollment; Finance; Human Resources; Academic Libraries


As we reported in May, the U.S. Department of Education was ordered by a U.S. District Court in California to implement the 2016 State Authorization Regulations. Although the original effective date of the regulations was July 1, 2018, the Department delayed them until July 1, 2020 and began the process of negotiating and writing new regulations which are still expected to be released later this year. The lawsuit brought by student and consumer advocates and the National Education Association, a teacher’s union, sought to force the Department of Education to implement the 2016 regulations and on May 26, 2019 the courts sided with the NEA. As a result, the court ordered the Department to implement the rules right away.

The 2016 state authorization amendments required institutions to obtain approval from each state in which they enroll students via online, distance education, and/or correspondence programs, or participate in a state authorization reciprocity agreement that includes the states they’re enrolling students in. States were required to have a means for students to lodge complaints and as of last year every state except California (and a few U.S. Territories) have either established a complaint process and process for approving out of state entities or joined a reciprocity agreement like NC-SARA.

Recognizing the effect this would have, the court allowed the Department time to consider how to implement the rules, since many schools and colleges have been enrolling Californians with the understanding that the State Authorization regulations had been delayed. On July 22, 2019 the Department released an electronic announcement explaining that the State Authorization rules were put into effect retroactively on May 26, 2016, causing a scramble in the distance education world. Reports of as many as 80,000 to more than 100,000 students enrolled in distance education programs all around the country were suddenly in jeopardy of losing access to their federal financial aid. As an attachment to the electronic announcement the Department provided some information about states’ complaint processes and pointed out that California didn’t have one for its private non-profit and public institutions. California’s Bureau of Private Postsecondary Education handles complaints for out-of-state for-profit institutions.     

California acted quickly to establish a complaint process for these schools, and authorized BPPE through the California Department of Consumer Affairs to begin handling complaints beginning on July 29, 2019. In a statement, the DCA said they expect that the ED will find the proposed process satisfactory, so that California is following federal rules, affected colleges can inform their students of the process, and students will not lose Title IV federal financial aid funding.

Although the Department hasn’t historically approved or denied individual state complaint processes, the U.S. Department of Education and California Regulators appear to be coordinating closely to avoid any missteps that could prolong or further deny federal aid to students receiving distance education because their institutions cannot meet the complaint process requirement due to problems with state procedures. The nation’s college students wait for the Department’s decision. Considering the potential to disrupt the education of thousands of online students affected. a conclusion to this issue needs to be carried out swiftly.

According to WCET, 4-6 states and territories may still be out of compliance after noting that some complaint procedures in some states were unclear and may not meet the federal requirements. So far, they have not released the names of the states or territories in question.  Education Secretary Betsy DeVos has also called for NEA to drop its lawsuit which although unlikely to happen could also resolve this issue by allowing the Department to continue their original plan to delay the regulations until such time as new rules are carried out or states comply.


On July 17, the U.S. Department of Education’s Office of Federal Student Aid issued an Electronic Announcement regarding what they deemed an “active and ongoing exploitation” of a known vulnerability potential in some versions of Ellucian’s Banner software. According to FSA’s “Technology Security Alert, the vulnerability affects Ellucian Web Tailor versions 8.8.3, 8.8.4, and 8.9 and Banner Enterprise Identity Services versions 8.3, 8.3.1, 8.3.2, and 8.4. Pointing to advisory bulletin by the National Institute of Standards and Technology (NIST), FSA reported that hackers may be able to breach the system through an institutional account and could then potentially use that access to set up “thousands of student fake student accounts”. The Department says that 62 colleges or universities have been identified which may be affected. Federal Student Aid’s Cyber Incident Team is working with institutions to identify if systems were impacted and to facilitate the necessary fixes. FSA asked institutions using Ellucian Banner to do the following:

  1. review the vulnerability details as provided in NIST advisory CVE-2019-8978;
  2. contact Ellucian to receive information needed to patch or upgrade affected systems; and
  3. respond immediately to the Department via email to both and
  • Include the following information in your email:
  • Institution’s Name
  • Information Technology (IT) Contact at Institution (Name, Email Address, Phone Number)

Ellucian has since pushed back on ED’s characterization of the nature of breach and its impact, stating that Banner’s potential software vulnerabilities, which were brought to light by both Ellucian and the National Institute of Standards and Technology in May, are unrelated to some of the other cybersecurity concerns outlined by ED. Ellucian said neither they nor ED have reason to suspect that a breach occurred as a result of the Banner software vulnerability. Schools using the impacted software should implement the system patch issued by Ellucian in May, if they have not already done so.

This is the second summer in a row that ED released a Technology Security Alert. In August of 2018, FSA released a warning about a malicious phishing campaign aimed at student email accounts. Officials cautioned that cybercriminals could change student account information including information such as direct deposit banking information which could be used to funnel student refunds and aid distributions into accounts controlled by the attackers. FSA offered this guidance to institutions:

How to protect IHEs: FSA strongly encourages IHEs to strengthen their cybersecurity posture through the use of two-factor or multi-factor authentication processes. These types of authentication rely on a combination of factors, for example, username and password combined with a PIN or security questions or access through a secure, designated device.

If you believe your institution has fallen victim to an attack, report the incident immediately to and Include the following:

  • Name of the institution
  • Date the incident occurred (if known)
  • Date the incident was discovered
  • Copy of the phishing email (if available)
  • Extent of the impact (number of students)
  • Remediation status (what has been done since discovery)
  • Institution point of contact

Suggested remediation steps if an institution falls victim to the attack:

  • Temporarily freeze refund requests until the scope of the incident can be known. Note, refunds must still be provided within regulatory guidelines which may require a change in how impacted IHEs issue refunds, e.g. issue paper checks.
  • Temporarily disable changes to direct deposits for refunds.
  • Block IP addresses observed in institution logs related to the attack.
  • Disable campus credentials or passwords for potentially affected students and require password resets.
  • Perform additional forensic analysis on server and application logs from recent weeks.
  • Notify all students, warning them of active phishing attempts and encourage them to be vigilant and careful about using links and entering personally identifiable information into websites.

UPDATED – On Tuesday August 6, the Department of Education released an updated Technology Security Alert regarding the vulnerability in Banner Web Tailor and Banner Enterprise Identity Services.

The Department dialed back their claims that Banner products were affected and instead point to vulnerabilities in “third-party software” being used as “front-end access points to the Ellucian Banner System and similar administrative tools”. The Department also confirmed what Ellucian has been saying all along – “To date, based on reports from targeted institutions, we have not found any instances where the Ellucian Banner System vulnerability has been exploited or is related to the issues described in the original alert.”

In an emailed statement from Ali Robinson, an Ellucian spokesperson, he said

“Research by the Department has found:

  • no instances where the known Banner vulnerability has been exploited or where it is related to the issues described in the original alert.
  • an industry-wide issue in which attackers use automation tools to submit fraudulent admission applications in order to obtain new student accounts.

Additionally, I should note that, Ellucian has conducted its own research and monitoring that has produced no evidence of any attempt to attack the known Banner vulnerability.”

The Department is advising institutions to  review any third-party front-end applications to ensure that they are not introducing unpatched vulnerabilities, or increasing the risk of potential future issues through automation attacks. The Department reccommends that insitutions implement human validation checks as part of their front-end portal submission process.



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.


NSLDS is gearing up to begin sending Enrollment Reporting Compliance Notifications in June 2019.  NSLDS Newsletter 64 provides some insight as to what’s to come for schools that fail to report enrollment status timely and properly. Here’s what is says:

Compliance Notifications will be sent to schools that are not reporting Program-Level enrollment information for a sufficient portion of their students. NSLDS tracks whether a school has reported Program-Level enrollment information for at least 90% of the students on its Enrollment Reporting Roster. 

When NSLDS determines that a school does not meet the 90% minimum threshold, the school will receive an initial warning notification from NSLDS, addressed to the school’s Financial Aid Administrator (FAA) and the Enrollment Reporting Contact, as provided on the ORG tab of the NSLDS Professional Access website.

If your school has not yet provided an Enrollment Reporting Contact for each of its locations, such as a representative from the Registrar’s Office, please do so as soon as possible. Note that this contact cannot be someone from a school’s third-party servicer.

Schools will receive a separate Enrollment Reporting Compliance Notification for each of its locations that are under the 90% threshold. 

If the school’s reporting performance does not improve, the school will receive a second warning notification addressed to the FAA and to the Enrollment Reporting Contact, with the school’s President or CEO copied.

If the school’s performance still does not improve after two warning notifications, it will receive a third notification that the school has been referred to Federal Student Aid’s Program Compliance office for consideration of possible sanctions.

This third notification will be addressed to the school’s President/CEO, with copies to the school’s FAA and Enrollment Reporting Contact.  The Program-Level reporting threshold is set at 90% to allow for instances in which a school may have a small percentage of students included on its NSLDS Enrollment Reporting Roster who are not enrolled in academic programs. While these students are not receiving aid at the reporting institution, they are enrolled in, for example, continuing education coursework.