1. MASFAA Conference November 7, 2012

2. Satisfactory Academic Progress2 Authority Provisions of New SAP Regulations School Requirements Definitions, Terms & Conditions Evaluations Best Practices Appendix

3. Program Integrity regulations: –Published October 29, 2010; –SAP requirements:  New requirements effective July 1, 2011  All SAP requirements consolidated into one regulatory provision – §668 (see Appendix) New SAP regulations: –Bring requirements up to date (last revised in 1983); –Make terminology more consistent; –Eliminate repeated, sequential use of probationary periods; and –Present a more structured, comprehensive and consistent approach. Satisfactory Academic Progress3

4. Continued flexibility for institutions to establish SAP policies for distinct categories of students. Evaluation within defined categories must be consistent and may include: –Full-time or part-time enrollment; –Undergraduate or graduate level; or –Different undergrad standards for freshmen, sophomores, juniors, and seniors regarding GPA and pace requirements at each grade level. –Increased flexibility if institutions monitor SAP more often than annually. –Definitions of “warning” & “probation,” including descriptions & conditions surrounding those statuses. –Measurement of a student’s progress at each evaluation:  Annually, each payment period, or less often than each payment period, but must occur at the end of a payment period. Satisfactory Academic Progress4

5. Incorporate the terminology used in the regulations; Clearly explain the conditions of each term; Clearly outline required elements: –GPA (i.e., qualitative standard); –Pace of progression to ensure completion within the maximum time frame (i.e., quantitative standard); –How a student’s GPA & pace are affected by incompletes, withdrawals, repetitions, or transfers of credit; –How an institution must count transfer hours accepted for program completion as both hours attempted & hours completed; –Specific elements & process required for appeal; and –How a student can reestablish eligibility. Satisfactory Academic Progress5

6. 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 can continue to receive Title IV aid for one payment period. No appeal necessary for this to occur. Financial Aid Probation Status assigned to a student who fails to make SAP, has appealed, and has had eligibility for Title IV aid reinstated. Institutions can impose conditions for student’s continued eligibility to receive Title IV aid. Satisfactory Academic Progress6

7. Appeal Process by which a student, who is not meeting SAP, petitions the institution for reconsideration of eligibility for Title IV aid. Must specify the conditions under which student may appeal. Appeal must include: –Why the student failed to make SAP; and –What has changed that will allow the student to make SAP at the next evaluation. Appeal can be approved only if the school: –Has determined student will be able to meet SAP standards after the subsequent payment period; or –Develops an academic plan with the student that, if followed, will ensure the student is able to meet SAP standards by a specific point in time. Satisfactory Academic Progress7

8. Academic Plan If one payment period is insufficient to meet minimum SAP standards, school may consider a long-range academic plan. Plans should be tailored to individual student needs. Elements that may be part of academic plan include: –Registering for fewer credit hours; –Achieving a minimum GPA at end of the probationary period (a term- specific GPA indicating upward movement from a very low cumulative GPA); –Achieving minimum course- specific grades; –Enrolling in and demonstrating academic success in certain courses. Plans should be developed by several offices, such as: –Academic advising, counseling, registrar, residence life, academic colleges, academic departments, student support, student life, student development, etc. as appropriate Satisfactory Academic Progress8

9. Pace Defined as the student’s progression to ensure completion within the maximum time frame Must be measured at each evaluation A graduated pace standard is still permitted, such as: 1st term – 50%; 2nd term – 60%; 3rd term – 70%, etc. Pace calculation: Cumulative # of credit hours completed ÷ Cumulative # of credit hours attempted = Pace/Quantitative Progress Other requirements (see Appendix) Maximum Time Frame Restricted to 150% of the published length of the student’s program (see additional details in Appendix) Satisfactory Academic Progress9

10. Evaluation at end of payment period for AY or shorter AYs End of each payment period or at least annually Determine when a warning period is required Notifications to students –Loss of eligibility –Financial aid warning –Financial aid probation –Academic plan requirements Program shorter than two years Program longer than two years –GPA of at least C –Academic standing consistent for graduation Satisfactory Academic Progress10

11. Policy is at least as strict as the policy the institution applies to a student who is not receiving Title IV aid. Policy provides for consistent application of standards to all students within categories of students, e.g., full-time, part- time, undergraduate, and graduate students, and educational programs established by the institution. Policy must define the following elements: –GPA or other comparable assessment measured against a norm; –The pace at which a student must progress to complete the program within the maximum time frame; –Process for incompletes, withdrawals, repetitions, and transfer of credit from other schools ; –Frequency of SAP evaluation; (continued next slide) Satisfactory Academic Progress11

12. Policy must define the following elements (cont’d): –SAP Warning (applicable only if school’s policy places student on financial aid warning); –SAP Probation (applicable only if school’s policy places student on financial aid probation); –SAP Appeal (applicable only if school’s policy places student on financial aid probation); student must appeal before probation granted; –Process for schools that evaluate SAP at the end of each payment period; –Process for schools that evaluate SAP annually or less frequently than the end of each payment period; and –Required SAP Notifications. Satisfactory Academic Progress12

13. Satisfactory Academic Progress13

14. Is the policy evaluated periodically to ensure its effectiveness and appropriateness? Is the policy published in appropriate institutional literature and/or on the institution’s web site? Is the policy provided to prospective students by posting it on an Internet web site or by sending publication or other documents via the U.S. Postal Service or e-mail? If the written policy is only distributed to students via a web site is notice sent to these students informing them of the exact web site address for the SAP policy and does the notice state that a written copy will be provided upon request? Is the policy made available to appropriate faculty advisors, counselors, and other institutional personnel and are they familiar with it? Satisfactory Academic Progress14

15. Are the following addressed in SAP Policy? −Non-punitive grades (WD, W, etc.) and repeated courses −Audited and pass/fail courses −Withdrawal and nonattendance −Incomplete grades Does the policy address transfer credits in determining SAP? Is the SAP policy for students receiving federal student aid at least as strict as the policy used for students not receiving federal student aid? Are the evaluation periods or increments established not to exceed the lesser of one academic year or one-half the published length of the education program? Satisfactory Academic Progress15

16. If the institution has an academic policy that allows for academic amnesty or renewal, does SAP policy clearly indicate that any such academic amnesty does not apply? Does the policy define qualitative and quantitative measures such as: maximum time frame, GPA, and completion rate, and are they consistently applied? Satisfactory Academic Progress16

17. Has the institution chosen to allow for an appeal process for students with mitigating circumstances, and if so, has it explained what circumstances may be considered? How are students notified of the appeal process? Does the policy identify the appropriate official(s) who approve the appeals? What constitutes documentation for an appeal? How are students notified of appeal decision? What office tracks appeals? Satisfactory Academic Progress17

18. Is the procedure evaluated periodically to ensure its effective and efficient. Are the student records reviewed in a timely manner at the end of each defined evaluation period or increment? Does policy address how data on SAP evaluations are maintained for statistical review? Satisfactory Academic Progress18

19. Are they included as a condition of a financial aid warning status, a financial aid probation status, or the approval of an appeal at the school’s option? Do they state the number of payment periods until student may come into SAP? Do they allow for: −Registration for fewer credit/clock hours −Registration in specified courses −Certain term grade point average requirements Satisfactory Academic Progress19

20. Do they have clear minimum standards? Do they allow for revisions? What constitutes a contract violation and what happens when a contract is violated? Satisfactory Academic Progress20

21. Challenges we faced: Qualitative –vs- Quantitative Warm and Fuzzy -vs- Standards and Expectations Student Retention -vs- Reality Satisfactory Academic Progress21

22. Satisfactory Academic Progress22

23. Satisfactory Academic Progress23

24. Satisfactory Academic Progress24 Reiterates SAP policy. Multi Semester. Clearer Goals. Special Program Identification.

25. Utilize your software. Talk with other institutions. Forge relationships. Don’t feel guilty. Satisfactory Academic Progress25

26. Joan Crissman, Assistant to the President for Strategic Development EC Group, LLC: www.ecgroupllc.orgwww.ecgroupllc.org Email: jcrissman@ecgroupllc.orgjcrissman@ecgroupllc.org Phone: (202) 257-6457 Kevin DeRuosi, Financial Aid Administrator Salem State University Email: kderuosi@salemstate.edukderuosi@salemstate.edu Phone: (978) 542-6112 Satisfactory Academic Progress26

27. Previous SAP requirements & references included in three separate regulatory sections: –Administrative Capability §668.16(e) –Student Eligibility §668.32 (f) –Satisfactory Progress §668.34 Now all requirements are consolidated into §668.34, with cross-references in §§668.16(e) & 668.32(f) Satisfactory Academic Progress27

28. Pace (cont’d from slide 9) –Institutions are still not required to include remedial coursework in calculation of pace. –Institutions should carefully consider how any remedial courses are defined in terms of completed and attempted hours, and appropriately describe how these courses enter the calculation of pace for SAP purposes. –SAP policy must describe how the pace calculation will be affected by course incompletes, withdrawals, repetitions, and transfer of credits from other institutions. –Credit hours accepted from another institution toward the student’s educational program must count as both completed and attempted hours in the calculation of pace. Satisfactory Academic Progress28

29. Pace (cont’d) –Regarding changes of major/academic program, schools have flexibility to determine how they impact SAP:  School policy could say that only credits counting toward the student’s current major are considered in the calculation of pace and the maximum time frame.  A more stringent policy might restrict a change in major to two or three times and not have credits specific to the earlier majors count against maintaining SAP; or  Provide that major changes before a certain point in the student’s program (e.g., before the third year in a four-year program,) do not impact SAP. Satisfactory Academic Progress29

30. Maximum Time Frame (cont’d from slide 9) –For credit hour programs, the maximum time frame cannot exceed 150% of the published length of the educational program, measured in credit hours; –For clock hour programs, the maximum time frame cannot exceed 150% of the length of the educational program, as measured by the cumulative number of clock hours required for completion, and expressed in calendar time. Satisfactory Academic Progress30

31. A student’s academic progress must be evaluated at the end of each payment period if the educational program is either: –One academic year in length or shorter than an academic year For all other educational programs, the institution may evaluate SAP at the end of each payment period or at least annually to correspond with the end of a payment period. Institutions must be sure to know when they may use a financial aid warning period based on the frequency of their SAP evaluation periods. Satisfactory Academic Progress 31

32. Institutions that evaluate SAP each payment period should notify students that they – –May lose eligibility for Title IV aid; –Can be placed on financial aid warning for one payment period; –Must make SAP or can be placed on financial aid probation after an appeal. Institutions that evaluate SAP each payment period after financial aid probation should notify students that they – –Must be making SAP, or –Are successfully following an academic plan. Satisfactory Academic Progress32

33. Institutions that evaluate SAP less often than each payment period should notify students that they – –May lose eligibility for Title IV aid; –May be placed on financial aid probation after an appeal; –Must be making SAP or successfully following an academic plan, after serving a probationary period. Satisfactory Academic Progress 33

34. For programs shorter than two years –Students must have an academic standing consistent with graduation standards. For programs longer than two years –Institutions have flexibility in defining the GPA requirement of their SAP policy. –At the end of the second academic year, the student must have –  GPA of at least a “C” or its equivalent; or  academic standing consistent with the institution’s requirements for graduation. Satisfactory Academic Progress34

35. Repeated Coursework Restricts number of times a student may repeat a course and receive Title IV financial aid for it. Must be considered in an institution’s SAP policy as it relates to the definitions of: –Completed hours and attempted hours; and –The impact of the repeated coursework on a student’s GPA. Notifications Results of a SAP review that impact the student’s eligibility. Describe the specific elements required to appeal SAP. If no appeal process, must describe how a student reestablishes eligibility. Satisfactory Academic Progress35

36. Preamble to the Program Integrity Final Regulations, October 29, 2010, p. 66879 https://www.ifap.ed.gov/fregisters/FR102910Final.html Satisfactory Academic Progress Reviews for Students in Clock Hour Programs, E- Announcement, June 6, 2011 https://www.ifap.ed.gov/eannouncements/060611SAPReviewforStudentsinClockHrs.html Program Integrity Questions and Answers - Satisfactory Academic Progress http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/sap.html Satisfactory Academic Progress Policies & Procedures & FSA Assessments, for 2010-11 and prior, and 2011-12 award year and beyond http://ifap.ed.gov/qahome/qaassessments/sap.html NASFAA 2011 Training Materials -- Satisfactory Academic Progress http://www.nasfaa.org/training/archives/Satisfactory_Academic_Progress_- _2011_Workshop_Kit.aspx Satisfactory Academic Progress36