May, the month where financial aid administrators pivot from recruiting new students to ensuring enrolled students have the wherewithal to continue. A critical part of the eligibility check for returning students is ensuring each is making satisfactory academic progress (SAP) as defined by the Department of Education (ED). First, we’ll review the basics and then discuss exceptions allowed due to COVID-19.
In general, SAP review must be conducted at the end of each payment period but may be done more often. Institutions must create a SAP policy for Title IV aid recipients that is at least as strict as the one in place for non-aided students. Institutions may have differing policies for different academic programs, but otherwise, the policy should be consistent across students and types of Title IV aid. For programs longer than two years, students must have at least a ‘C’ average or standing consistent with graduation requirements at the end of the second year of study.
There are two components to the review – a qualitative component (grades) and a quantitative component (successful course completion). Other than what was mentioned above, the ED does not have a grade requirement. Institutions most often align the financial aid policy with the general academic policies. For undergraduate programs, the quantitative review requires the student to be working at a pace to complete the program in at most 150% of the published timeframe. For clock-hour programs, the 150% timeframe refers to calendar time not clock hours. For graduate and professional programs, both components are determined by the institution. The same classes have to be included in both assessments except in the case of remedial courses, which must be included in the qualitative review, but it is the institution’s option whether to include them in the quantitative review. Finally, institutions determine which classes to include in the review for students changing majors.
Institutions that review SAP at the end of each payment period (term, semester, etc.), may place aid recipients not meeting the standard on Financial Aid Warning without an appeal from the student provided the student was meeting the standard up until the most recent payment period or the student is in the first payment period of the program. All institutions may allow students to submit an appeal and, if successful, be placed on Financial Aid Probation for one payment period or more depending on how long it will take the student to return to good standing. If the probation period will be longer than one payment period, the institution must also create an academic plan for the student and closely monitor compliance. The appeal itself should address the reason for the poor academic performance and how the student plans to remedy the situation. A student who loses aid eligibility because of SAP can only regain it by successfully completing course work related to his/her degree program – whether at the home institution or another.
Section 3509 of the CARES Act allows some flexibility when it comes to assessing the quantitative component of SAP. In particular, without an appeal from the student, an administrator may exclude any attempted credits not completed due to a reason related to the COVID – 19 national emergency (illness/family member illness; became a care giver or first responder; economic hardship; additional work hours; loss of childcare). Additionally, if the campus ceased operations for any amount of time, classes that could not be completed due to the student’s inability to participate in distance education (inability to access wi-fi, for example) may also be excluded. For the calculation, the credits are excluded from both the measurement of pace (the payment period in question) and the maximum timeframe (total credits needed to successfully complete the program).
SAP is certainly not the only aspect of financial aid that was impacted by COVID-19 related academic calendar changes. Check out HEAG’s presentation, When the Axis Shifts: Academic Calendar Changes and the Impact on Financial Aid, to learn more.