Surviving Satisfactory Academic Progress

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Surviving Satisfactory Academic Progress

• SASFAA Conference
• February 2008
• Arlington, VA

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• Marie Bennett
• Dow Lohnes, PLLC
• Washington, DC
• mbennett_at_dowlohnes.com
• 202-776-2599

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Session Overview

• What is SAP?
• What Governs SAP?
• What Tips Can Help?
• What are the Compliance Pitfalls?
• Checklist

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What is Satisfactory Academic Progress?

• A TIV Eligibility requirement established by
  school using parameters set by law
• Measurement of Student Progress toward completing
  educational program for all disbursements after
  the first one

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Components of Measurement

• Qualitative
• GPA (current and cumulative)
• Other grade measurement if GPA not used
• Quantitative
• 150 (undergraduate) or other (graduate) Limit
• Measured in Credit, clock hour, or weeks/months
• Regular and equal intervals

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What Governs SAP? Laws, Regulations, Guidance

• 1. Higher Education Act (HEA 484)2. Code
  of Federal Regulations (34 CFR)
• 3. FSA Handbook

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HEA 484(a)(2)

• In order to receive any grant, loan or work
  assistance under this title, a student must
  (2) If the student is presently enrolled at an
  institution, be maintaining satisfactory progress
  in the course of study the student is pursuing. .
  .

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HEA 484(c)

• . . . A student is maintaining satisfactory
  progress if (A) the institution at which the
  student is in attendance reviews the progress of
  the student at the end of each academic year or
  its equivalent

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HEA 484.(c)(B)

• the student has a cumulative C average or its
  equivalent or academic standing consistent with
  the requirements for graduation, as determined by
  the institution at the end of the second such
  academic year.

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34 Code of Federal Regulations668.16(e)Admin.
Cap. Provision

• Each school must establish, publish and apply
  reasonable standards for measuring satisfactory
  academic progress

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34 Code of Federal Regulations668.16(e)

• A schools standards are considered reasonable
  if the standards are the same, or stricter than
  the institutions standards

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34 Code of Federal Regulations668.16 (e)

• Standards must include qualitative and
  quantitative components

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34 Code of Federal Regulations668.16 (e)

• Standards must be consistently applied within
  categories of students, provide a timeframe for
  determination, include appeal procedures and
  procedures to re-establish satisfactory academic
  progress compliance.

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34 Code of Federal Regulations668.32(f) Student
Eligibility

• A student is eligible to receive Title IV HEA
  program assistance if the student . . . (f)
  maintains satisfactory progress in his or her
  course of study according to the institutions
  published standards . . .

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34 Code of Federal Regulations668.34

• If a student is enrolled in a program of study
  of more than two academic years, in order to be
  eligible to receive Title IV funds, the student
  must (in addition to satisfying the requirements
  contained in 668.32(f)) be making satisfactory
  progress under the provisions of paragraphs b, c,
  and d of this section

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• (b) Has a C or its equivalent GPA
• (c) Unless hardship of death of relative injury
  or illness or student or other special
  circumstance
• (d) Reinstate for subsequent grading period when
  grade average is obtained
• (e)At a minimum review once a year

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34 Code of Federal Regulations 668.42

• Schools must publish and make readily available
  to current and prospective students the standards
  which the student must maintain in order to be
  considered to be making satisfactory academic
  progress and the criteria by which the student
  who failed to maintain satisfactory progress may
  re-establish his or her eligibility for financial
  assistance.

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FSA Handbook Guidance Volumes 1 and 2

• Anytime a student cant complete program within
  maximum time frame
• Explain mitigating circumstances if allowed in
  appeal and Document
• Document at each disbursement along with all
  eligibility criteria

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More Guidance

• No Amnesty
• All Grades (Repeat, remedial, W, I, etc.)
• All enrollments (Transfer, Repeat, etc.)
• Equal Increments
• Conditional or probationary
• Regain eligibility

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SAP Policy Development

• Involve your Title IV school partners (e.g.
  Academic, Registrar, Bursar)
• Outline the requirements for undergraduate and
  graduate students include program specific
  requirements if applicable
• Define the effect of incomplete course grades,
  repeated courses, non credit remedial courses,
  withdrawals, etc.

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SAP Policy Development

• Define the effect of transfer credits
• Outline the procedures to re-establish
  eligibility
• Outline the appeal process procedures for
  students who fail to meet the SAP standards

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The Magic of SAPEarly Identification and
Intervention

• Academic Challenges
• Personal Challenges
• Financial Challenges
• Medical/Mental
• Challenges
• Social Adjustment Challenges

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Before and During Warning and Probation

• Intervention Strategies with your partners
• FinancialFinancial Aid Office (budgeting,
  alternative resources)
• AcademicTutoring, Study Skills, Academic
  Advising
• SocialHousing and Student Services
• PersonalTime Management

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Benefits of SAP

• Benefits to Institution
• Students academic success
• Higher retention rates
• Higher student satisfaction rate
• Communication
• Opportunities to assist the academic community in
  understanding SAP
• Students may reach a higher level of connection
  to campus

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Benefits of SAP

• Benefits to Financial Aid Office
• Fewer repeat offenders
• SAP policy/appeal
• process that is more than
• punitive
• Lower default rates

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Checklist

• Qualitative Component
• At least as strict
• Static or graduated
• Grade or equivalent
• C Average
• All Grades
• Transfer Credits and Repeat Courses
• Intervals

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Checklist, cont.

• Quantitative
• Maximum Time Program Length and Level
• Enrollment pattern consistency
• Program Delivery (Credit or Clock Hours, Academic
  Year Definition)
• Program Changes
• Attempted Completed (Remedial, Repeat,
  Incomplete, Withdrawal, Transfer, Absences etc.)
• Intervals of measurement

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Checklist, cont.

• Probation and warning periods
• Appeal Policy and Process
• Explain Mitigating/Special Circumstance
• Documentation
• How to Re-establish eligibility
• Eligibility at Each Disbursement
• Publication

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Tell me

• Whats worked at your school?
• How often do you review SAP implementation
• QC of SAP implementation?
• Programming of policy or hand calculations?
• Letters to students?
• Questions?

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• Marie Bennett
• Senior Manager
• Higher Education Services
• Dow Lohnes, PLLC
• Washington, D.C.
• MBennett_at_dowlohnes.com
• [phone]