Many People Hands Holding Red Word Asap Blue SkySatisfactory Academic Progress (SAP) policy problems consistently make the U.S. Department of Education’s List of Top 10 common—and often expensive—Federal Student Aid program review findings. In short, under-developed SAP policies can lead colleges and universities to award Federal Student Aid funds to ineligible students—funds those schools must ultimately return to the Department. Findings related to SAP can even contribute to ending a school’s Federal Student Aid participation.

But there’s good news! Even if you don’t work in the financial aid office, it’s (fairly) easy to ensure your SAP policy includes required elements. You can find your policy published online or in your catalog. (If it’s not, it should be.).

Take a quick look and see if your SAP policy has these required elements. (See here, here, and here for more detail.)

  • Consistent treatment of categories of students. Policy consistently applies standards within categories of students (e.g., full- or part-time, undergraduate or graduate, or by educational program).
  • Set times for SAP evaluation. Policy states that SAP is evaluated at the end of each payment period or a least annually.
  • GPA. Policy specifies the GPA (or comparable assessment) that students must achieve at each evaluation.
  • GPA 2.0. For students in educational programs of more than two years, policy specifies that their GPAs must be at least “C” or the equivalent—or that students have standing consistent with graduation requirements—at the end of the second year.
  • 150% timeframe. Policy includes a maximum timeframe in which students must complete their programs: for undergraduate programs, maximum timeframe is no more than 150% of the published length of the program; for graduate programs, maximum timeframe is defined by the school based on program length. (Note that the Department wants schools to find that students fail SAP timeframe standards at the point where it is mathematically impossible for them to complete within the policy’s maximum timeframe.)
  • Pace. Policy specifies the pace at which a student must progress through a program to complete within the maximum timeframe.
  • Pace formula. Policy says that pace is measured by dividing the number of hours the student has successfully completed by the number of hours the student has attempted (but remedial courses need not be included).
  • Miscellaneous courses. Policy describes how GPA and pace of completion are affected by course
    • Incompletes,
    • Withdrawals,
    • Repetitions, and
    • Transfers of credit.
      • Credit hours from other institutions accepted towards the student’s program count as both attempted and completed.
  • Failure to make GPA or pace. Policy provides a student not achieving SAP standards is no longer eligible for Federal Student Aid funds unless (and these are both optional):
    • If evaluate SAP at end of payment period, the student (a) is placed on financial aid warning or (2) has appealed successfully and is placed on financial aid probation.
    • If evaluate SAP less frequently than at end payment period, the student has appealed successfully and is placed on financial aid probation.
  • Appeals. If the school permits appeals, policy describes
    • Bases on which students may file appeals, and
    • Information students must submit with appeals.
  • Financial Aid Warning & Financial Aid Probation: If the school places students on financial aid warning or financial aid probation, policy
    • Describes these statuses;
    • States that a student may receive Federal Student Aid funds while on financial aid warning or financial aid probation for one payment period;
    • Describes the process for academic plans if the school will require students on financial aid probation to fulfill an academic plan; and
    • Requires that a student on financial aid probation meet the school’s SAP standards or the requirements of the academic plan in order to avoid again losing eligibility for Federal Student Aid funds at the end of the period of probation.
  • Regaining eligibility. Policy explains how students who lose eligibility for failure to meet SAP standards may regain it—e.g., by meeting SAP standards (without Federal Student Aid funding) or through successful appeal with probation.
  • Notification. Policy provides that students are notified of SAP evaluation results that impact student Federal Student Aid eligibility.

See A Guide to Creating a Policies and Procedures Manual (Section 1, pp. 11-14).

What this means to you

SAP continues to be one of the most challenging Federal Student Aid compliance matters in the face of growing student populations, shifting educational platforms and schedules, and increasing transfers between institutions. Administrators, academics, and the financial aid office—who collectively know the most about your institution’s programs and practices—should consider working together on compliant SAP administration. A solid SAP policy serves as a launching point for (1) keeping students on track to completion, (2) performing compliant SAP evaluations, and (3) avoiding substantial SAP liabilities.

*Lisa Hoskins is a Federal Student Aid consultant with Husch Blackwell’s Education team. A former Institutional Review Specialist with the U.S. Department of Education, Office of Federal Student Aid, and Financial Aid Manager, Lisa works with Husch Blackwell’s team of Education attorneys in guiding clients through detailed Title IV Federal Student Aid issues, reviews, and program review responses.