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Program Integrity Q&A

Questions  on this topic are divided into the following categories:
- **General Questions** 
- **Satisfactory Academic Progress  Reviews**
- **Financial Aid A** **ppeals**
- **Financial Aid Warnings**
- **Financial Aid Probation**
- **Academic Plans**

In addition to the following Q&As, please see the following resources for guidance related to Satisfactory Academic Progress:
- Preamble  to the final regulations ( https://www.govinfo.gov/content/pkg/FR-2010-10-29/pdf/2010-26531.pdf ) – published 10/29/2010
- E-Ann   ((General) Subject: Satisfactory Academic Progress Reviews for Students in Clock Hour Programs | Knowledge Center " ) – published 6/6/2011

**General Questions (SAP)**

SAP-Q1: The Satisfactory Academic  Progress (SAP) regulations became effective on July 1, 2011.  Does this mean that the institution must  measure SAP after a summer 2011 payment period using the new regulations?

SAP-A1:  Not necessarily.  The institution must  have a SAP policy that complies with the new regulations as of July 1, 2011;  however, various factors could influence when the first review using the new  regulations takes place, such as how frequently the institution measures SAP,  whether the student is enrolled during a summer 2011 payment period, and, if  so, whether that payment period is a cross-over payment period (i.e., includes  both June 30 and July 1).  For a summer  2011 crossover payment period, an institution can use either the prior SAP  regulations - those that were in effect prior to July 1, 2011 - or the new SAP  regulations.  However, if a student’s  summer enrollment was in a payment period that was not a crossover period, the  SAP requirements that must be used are those for the year of the non-crossover  summer period.  That is, if the summer  payment period ended on or before June 30, 2011, the prior SAP rules apply and  if the summer payment period began on or after July 1, 2011, the new SAP rules  apply.

While  the following summer 2011 scenarios are presented for a standard term  institution with an optional summer term, the guidance is also applicable for  programs offered under other calendars.

STUDENT ENROLLS SUMMER 2011
- Prior  Rules – Annual Evaluation:  If the  institution uses the prior SAP regulations for the summer 2011 payment period  and evaluates SAP annually beginning at the end of the summer payment period,  the first SAP review under the new regulations will occur after the summer 2012 payment period.
- Prior  Rules – Payment Period Evaluation:  If  the institution uses the prior SAP regulations for a summer 2011 payment period  and measures SAP at the end of each payment period, the institution would use  the prior regulations for the review at the end of the summer 2011 payment  period and the new regulations for the review at the end of fall 2011 payment  period.
- New  Rules – Annual Evaluation:  If the  institution uses the new SAP regulations and measures SAP annually, it is  possible that the first evaluation under the new SAP regulations could take  place after the summer 2011 payment period, after the fall 2011 payment period,  or after the spring 2012 period depending on when in the year the institution  has chosen to do its annual SAP evaluation.
- New  Rules – Payment Period Evaluation:  If  the institution uses the new SAP regulations for summer 2011 and measures SAP  at the end of each payment period, the institution would use the new  regulations to measure SAP at the end of the summer 2011 payment period.

STUDENT DOES NOT ENROLL SUMMER 2011
- Annual  Evaluation:  If the student does not  attend summer 2011 and the institution measures SAP annually, the first evaluation  under the new regulations could take place after the fall 2011 payment period,  after the spring 2012 payment period, or after the summer 2012 payment period.
- Payment Period Evaluation:  If the student does  not attend during the summer of 2011 and the institution measures SAP after  each payment period, the first evaluation under the new regulations would take  place after the fall 2011 payment period.

[Guidance issued 8/26/2011]

SAP-Q2:  Must schools adopt the terminology, such as warning and probation, used in the  regulations?

SAP-A2:  Yes.  The preamble to the October 29,  2011 final regulations (75 FR 66884) states that institutions must incorporate  these regulatory changes into the information they provide to students; this  includes ensuring that the information made available by the institution uses  the terminology used in the regulations.   Therefore, to the extent that your institution uses the statuses we  describe in the new regulations, it must use the terminology in the  regulations. [Guidance issued 8/26/2011]

SAP-Q3:  How are remedial courses treated for SAP purposes?

SAP-A3: The institution's SAP policy should describe how remedial courses are treated. If the student is admitted into an eligible program and takes remedial coursework within that program, he can be considered a regular student, even if he is taking all remedial courses before taking any regular courses. Because an institution may include up to one academic year’s worth of remedial courses when determining a student’s enrollment status for federal student aid, those remedial courses must be included for purposes of the student’s qualitative SAP component; however, the courses need not be included in the student’s GPA.   An institution may calculate a GPA used for SAP purposes that includes the grades from the remedial courses or may use another method to determine the qualitative measure for this coursework.  Remedial courses are not required to be included for the quantitative component.  An institution may, but is not required to, include remedial coursework in determining pace.

A student enrolled solely in a remedial program is not considered to be enrolled in an eligible program and, therefore, is not a regular student.  If acceptance into an eligible program is contingent on completing remedial work, a student cannot be considered enrolled in that program until the student completes the remedial work. [Guidance issued 8/26/2011; **revised 10/19/2011**]

SAP-Q4:  How are English as a Second Language (ESL) courses treated for SAP purposes?

SAP-A4:  The institution's SAP policy should describe how ESL courses are treated.  Similar to other remedial coursework, a  student may receive Federal student aid for ESL courses that are part of an  eligible program.  As discussed above for  remedial courses, the new SAP regulations do not require an institution to  count remedial courses in determining pace.   [Guidance issued 8/26/2011]

SAP-Q5:  How should an institution handle changes of majors?  Can an institution limit the number of times  a student may change majors?

SAP-A5:  The treatment of a student who changes majors is determined by the institution  and should be specified in its SAP policy.   While the student aid regulations cannot impose academic restrictions on  institutions, an institution may specify in its SAP policy that it will include  coursework taken by a student for enrollment in other majors.  [Guidance issued  8/26/2011]

SAP-Q6:  The SAP regulations require that credit hours that are accepted toward the student’s educational program count as both attempted and completed when calculating pace for SAP purposes.  Can an institution’s policy include non-accepted credits as attempted credits for purposes of this calculation?

SAP-A6:  The SAP regulations do not address non-accepted credits.  The treatment of these credits would be up to the institution.  [Guidance issued 8/26/2011; **revised 11/18/2011**]

SAP-Q7:  Can the SAP pace requirements be different for students at different points in  their academic program?

SAP-A7:  Yes.  An institution may use a different  pace standard for students in different grade levels.  This could result in the pace gradually  becoming more strict.  For example, the  institution may use a 50% pace for first year students, a 65% pace for second  year students, and an 85% pace for third and fourth year students, rather than  using a flat 67% pace for each year.

In  addition, an institution’s SAP policy may specify a graduated pace, measured by  payment period.  Such a pace may be applicable to certain categories of  students, such as transfer students.  In addition, the policy would need  to articulate how the per-payment period pace would relate to the cumulative  pace calculation required by the regulations.   [Guidance issued 8/26/2011]

SAP-Q8:  How is repeated coursework treated for SAP purposes?

SAP-A8:  The treatment of a repeated course for SAP purposes would be up to the  institution. The institution's SAP policy should describe how repeated courses  are treated and affect a student’s GPA and pace of completion.  The institution may consider factors such as  whether the student previously received credit for the course.  [Guidance issued  8/26/2011]

SAP-Q9:  Is an institution required to use the same SAP policy for all students?

SAP-A9:  No, the policy must explain the qualitative (grade-based) and quantitative (time-related) standards the institution uses to check SAP; however, an institution is permitted to establish different SAP standards for different programs or categories (e.g., full-time, part-time, undergraduate, and graduate students) which must be applied consistently to students in that category or program. [Guidance issued 10/19/2011]

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**SAP Reviews (R)**

R-Q1: What constitutes a SAP review?  Is an  institution required to review both the qualitative (grade-based) and  quantitative (time-based) SAP measures?

R-A1: Yes.  A SAP review is not complete until both the qualitative and quantitative measures have been reviewed.  The institution must review both SAP measures on at least an annual basis; however, if the institution reviews SAP at each payment period in order to use the financial aid warning status, both SAP measures must be reviewed at each payment period.  A student who fails either measure becomes ineligible for aid.

Other  combinations are possible.  For example,  an institution may review the quantitative measure annually and review the  qualitative standard at every payment period; however, conducting SAP reviews  on this type of schedule would not be reviewing SAP at each payment period and  the institution would not be able to use the financial aid warning status.  [Guidance issued  8/26/2011]

R-Q2:  How does the qualitative portion of a SAP review relate to the requirement for  a student to have a GPA of at least 2.0, or academic standing consistent with  the institution’s requirements for graduation?

R-A2:  An institution’s SAP policy is required to include the GPA (or equivalent) a  student must achieve at each evaluation to be considered as making satisfactory  academic progress.  This qualitative  standard must be reviewed at each evaluation of the student’s progress.

In  addition, the Higher Education Act requires a specific qualitative review at  the end of the student’s second academic year.   In this context, we have interpreted the “second academic year” as the  student being at the school for 4 semesters or 6 quarters, regardless of a  student’s enrollment status.  At that  point, the student must have a GPA of at least a 2.0 or its equivalent or have  academic standing consistent with the institution’s graduation requirements.  [Guidance issued  8/26/2011]

R-Q3:  If a student is on SAP probation when the new SAP regulations become effective,  when must the student be evaluated?

R-A3:  If the student was placed on probation under the prior regulations, the student  is evaluated at the institution's next regular evaluation point under the new  regulations.  If the student is not  making SAP at that evaluation, the appropriate action depends on how frequently  the institution measures progress.  If  progress is measured at each payment period, the student could be placed on  financial aid warning.  If progress is  measured less frequently than every payment period, the student could be placed  on financial aid probation after a successful appeal.  [Guidance issued  8/26/2011]

R-Q4:  If an institution reviews SAP each payment period, must the institution also  review SAP after a summer term?

R-A4:  If an institution reviews SAP each payment period, the institution must review  SAP after a summer term if the student attends the summer term.  [Guidance issued  8/26/2011]

R-Q5:  If a student successfully appeals and is placed on probation under the new SAP  regulations, when must the student be reviewed?

R-A5:  The student must be reviewed at the end of one payment period on probation,  even if the institution’s SAP policy is that it reviews students annually.  This could mean that a student on financial  aid probation is reviewed on a different schedule than other students at the institution.  [Guidance issued  8/26/2011]

R-Q6:  A student is on an academic plan for failing to meet SAP standards.  When is this student reviewed?

R-A6:  If a student successfully appeals and is placed on SAP probation and on an  academic plan, the student’s SAP would be reviewed at the end of one payment  period, as is required of a student on probation.

After  the probationary payment period, the student’s SAP would be reviewed according  to the plan.  The plan could specify that  the review takes place at the next point when the rest of the institution’s  population is reviewed, which could mean every payment period or annually. The  plan could also specify that the student is reviewed more frequently than the  rest of the institution’s population; however, a student on an academic plan  would not be reviewed less frequently than the rest of the institution’s  population.  [Guidance  issued 8/26/2011]

R-Q7:  When is SAP measured for a clock hour program?

R-A7: Whether the institution reviews SAP at each payment period or annually, the regulations specify that for all programs, SAP is measured at the end of a payment period. 

The  institution’s SAP policy must establish the maximum timeframe and the pace  component for students in an educational program. The required SAP  evaluations ensure that the student is making appropriate academic progress to  complete his or her program within the context of these time-based  parameters.  Except as limited by the maximum timeframe permitted under  the institution’s policy, an institution must review a student’s academic progress in a program at the end of the payment period to determine if a  student is eligible for a subsequent Title IV payment by selecting one of the  following options for all students in a program:
- At the point when the student’s scheduled clock hours for the payment period have elapsed, regardless of whether the student attended them;
- At the point when the student has attended the scheduled clock hours; or
- At the point when the student successfully completes the scheduled clock hours for  that payment period.

The review option must be specified in  the institution’s policy and, as noted above, would be used in conjunction with  the regulatory requirements for pace (in 34 CFR 668.34(a)(5)) and maximum  timeframe in 34 CFR 668.35(b) for purposes of evaluating the student’s academic  progress.

Finally, in addition to taking one of the above review actions, in order for  the student to be eligible for the next payment under 34 CFR 668.4, the  institution must determine that the student has successfully completed both the  clock hours and weeks of instructional time required for that period.  [Guidance issued 6/6/2011; **revised 8/22/2012**] 

R-Q8:  The SAP regulations, at Sec. 668.34(a)(3)(ii), require that, for programs that are longer than one academic year, the student’s SAP must be evaluated “at the end of each payment period or at least annually to correspond with the end of a payment period;”.   In this context, what does “annually” mean?

R-A8:  In this context, annually means a 12-month period. An institution is expected to review a student’s SAP at least once every 12 months. [Guidance issued 10/19/2011]

R-Q9:  Can you provide an example of how pace would be calculated under the options presented in R-A7?

A-Q9:  We are using as an example, a 40 week, 1200 clock hour program in which a student is scheduled for 30 hours a week.  The maximum timeframe to successfully complete the 1200 clock hours is 150% of 40 weeks or 60 weeks.  Assuming that the institution reviews SAP at each payment period and uses a 67% completion rate to calculate pace, the following examples illustrate how an institution could apply the SAP review options as described R-A7.  Note that an institution must establish one review option for a program; the institution cannot start with one option and then after the first review, switch to a different option for that cohort of students.

Also note that pace is only one component of a SAP review.  In addition to the quantitative pace component, the qualitative grade-based component must also be assessed.  Finally, in order for the student to be eligible for the next payment under 34 CFR 668.4, the institution must determine that the student has successfully completed both the clock hours and weeks of instructional time required for that period.

Option 1:  The school reviews SAP based on scheduled hours, which is option 1 as described in R-A7.   At 450 scheduled hours, the student has successfully completed 300 hours.   Calculating in terms of hours, the pace would be 300/450 = 67% or, as expressed in calendar time, 10 weeks/15 weeks = 67%.  Note that both items must be checked according to definition of maximum timeframe in Sec. 668.34(b) and that standard rounding is allowed.  The student is making satisfactory academic progress but is not eligible for the second disbursement until he successfully completes 450 hours and 15 weeks of instructional time.  When the hours are successfully completed, the institution may make the second disbursement; however, the pre-disbursement review is not considered to be a SAP review.  The next SAP review is at 900 scheduled hours.

If the student was not making satisfactory progress at the first SAP evaluation, the institution could place the student on financial aid warning.  The student would be reviewed for his second disbursement when he completes 450 hours and 15 weeks of instructional time.  At this time, the student could receive the second disbursement; however the warning status would continue until the next SAP review at 900 scheduled hours.  If the student is not making progress at that SAP review, the student would need to successfully appeal to continue.

Option 2:  At the time 600 hours have elapsed, the student has attended 450 hours.  Calculating in terms of hours, the pace would be 450/600 = 75% or, as expressed in calendar time, 15 weeks/20 weeks = 75%.  Note that both items must be checked according to definition of maximum timeframe in Sec. 668.34(b) and that standard rounding is allowed.  Although the student has attended the hours, the student is not eligible for the second disbursement until he successfully completes 450 hours and 15 weeks of instructional time.

Option 3:  The student successfully completes the 450 hours required for the payment period at the point where he was scheduled to complete 600 hours.  This review point is option 3 as described in R-A7.  The calculated pace, in hours, would be 450/600 = 75% or, as expressed in calendar time, 15 weeks/ 20 weeks = 75%.   Note that both items must be checked according to definition of maximum timeframe in Sec. 668.34(b) and that standard rounding is allowed.  Because the student has successfully completed both the hours and the weeks in the payment period, the second disbursement would be made at this time. [Guidance issued 8/22/2012] 

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**Financial Aid  Appeals (APP)**

APP-Q1:  How many times may a student appeal a failure to make SAP?

APP-A1:  The regulations do not limit the number of times a student may appeal.  If an institution permits appeals, the  regulations (at 34 CFR 668.34(a)(9)) specify what the policy must include.  The policy must describe how the student may  reestablish his or her eligibility to receive Title IV aid and the basis on  which a student may file an appeal (such as the death of a relative, an injury  or illness of the student, or other special circumstances).  The institution's policy must also describe  the information the student must submit to support the appeal, including why  the student failed to make satisfactory academic progress, and what may have  changed in the student’s situation that will allow the student to demonstrate  SAP at the next evaluation.  If the  student appealed on the basis of one circumstance and wanted to appeal again  based on the same circumstance, the student would have to provide information  about what has changed to permit the student to make satisfactory progress at  the next evaluation.  In addition, an  institution may decide to limit the number of times it will allow a student to  appeal.  [Guidance  issued 8/26/2011]

APP-Q2:  What documentation is required for a student appeal?

APP-A2:  That is up to the institution.  An  institution may choose to request additional documentation when a particular  student circumstance warrants it.  The  institution may decide to require more extensive documentation on an initial  appeal and an update statement on a subsequent appeal.  [Guidance issued  8/26/2011]

APP-Q3:  Can a student appeal the 150% maximum timeframe?

APP-A3:  Yes.  The regulations do not prohibit a  student from appealing the maximum timeframe.   [Guidance issued 8/26/2011]

APP-Q4:  May an institution’s SAP policy include automatic “academic amnesty” in certain  circumstances, such as, after a student has not attended for a certain number  of payment periods or years?

APP-A4:  No.  The regulations permit use of the  automatic financial aid warning status for institutions that review SAP at each  payment period.  No other status may be  granted automatically.  A successful  appeal is needed to grant financial aid probation status or to develop an  academic plan.  [Guidance  issued 8/26/2011]

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**Financial Aid  Warning (WARN)**

WARN-Q1:  How long is the financial aid warning period?

WARN-A1:  Financial aid warning lasts for one payment period only and does not require  action (such as an appeal) by the student.   This option may only be used by an institution that reviews both SAP  measures at every payment period.  [Guidance issued 8/26/2011]

WARN-Q2:  Is there a limit to the number of financial aid warnings a student can receive  during his or her enrollment?

WARN-A2:  It is possible that a student could receive more than one financial aid warning  period.  For example, at an institution  that reviews SAP at every payment period if a student is not making SAP, the  student may be placed on financial aid warning.   The student could make SAP during the next payment period and then fail  to make SAP during the subsequent payment period. The student could again be  placed on financial aid warning.  The  student could not have successive periods in financial aid warning status.  [Guidance issued  8/26/2011]

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**Financial Aid  Probation (PROB)**

PROB-Q1:  Under what circumstances would a student be placed on SAP probation?

PROB-A1:  A student who fails SAP must successfully appeal to be placed on probation.  Probation may not be given  automatically.  At the end of one payment  period on probation, the student must make SAP or must be meeting the  requirements of the academic plan.  [Guidance issued 8/26/2011]

PROB-Q2:  If, after one payment period on probation, the student is still not making SAP,  can the student be automatically placed on an academic plan, or must the  student appeal again?

PROB-A2:  The student would have to successfully appeal to be placed on a plan.  The institution would need information about  why the student failed to make SAP at the end of the probation payment period,  including what had changed that caused the student to not make SAP during the  probationary payment period and why the student will be able to meet SAP on the  terms of the academic plan.  The student is on probation during the first payment period of the academic plan.  [Guidance issued 8/26/2011; **revised 04/13/2012**] 

PROB-Q3:  At an institution that permits appeals but does not use the financial aid  warning status, is probation required for a student who is not making progress?

PROB-A3:  Yes.  This answer clarifies recent  presentations on this issue.  A student  at an institution that does not use SAP warnings (either because it measures  SAP only annually or has chosen not to use warnings) who is not making SAP must  successfully appeal to continue to receive Title IV aid.  If the institution determines, based on the  appeal, that the student should be able to meet the satisfactory academic  progress standards by the end of the subsequent payment period, the institution  may place the student on probation without an academic plan.  The institution must review the student’s  progress at the end of that one payment period, as probation status is for one  payment period only.

If  the institution determines, based on the appeal, that the student will require  more than one payment period to meet SAP, it may place the student on probation  and develop an academic plan for the student.   The institution must review the student’s progress at the end of one  payment period as is required of a student on probation status, to determine if  the student is meeting the requirements of the academic plan.  If the student is meeting the requirements of  the academic plan, the student is eligible to receive Title IV aid as long as  the student continues to meet those requirements and is reviewed according to  the requirements specified in the plan.

This  guidance also applies to an institution that permits appeals and already has  used the warning status for a student who is not meeting SAP requirements.  [Guidance issued  8/26/2011]

PROB-Q4:  How many times may a student be placed on probation for failing to meet SAP  standards?

PROB-A4:  A student may be placed on probation for one payment period per appeal.   It is possible that a student could be placed on probation more than once in  his or her academic career.  [Guidance issued 8/26/2011]

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**Academic Plans (ACP)**

ACP-Q1:  How should an institution develop an academic plan for a student who  successfully appeals SAP ineligibility?

ACP-A1:  The regulations do not specify what must be included in an academic plan.  The institution and the student should  develop a plan that ensures that the student is able to meet the institution's  satisfactory academic progress standards by a specific point in time.  An academic plan could take the student to  program completion, rather than meeting the institution’s SAP standards at a  specific point in time.  [Guidance issued 8/26/2011]

ACP-Q2:  What is the status of a student who has completed the probationary payment  period and who is continuing to receive aid by meeting the requirements of the  student’s academic plan?

ACP-A2:  A student who has been reinstated to eligibility under an academic plan and is  making progress under that plan is considered to be an eligible student.  [Guidance issued  8/26/2011]

ACP-Q3:  Can the academic plan be the same for all students or the same by categories of  students or must the plan be established individually for each student?

ACP-A3:  According to the regulations (34 CFR 668.34(a)(8)(ii)), the academic plan is  developed by the institution and the student individually.  It is possible that a general plan could be  used for students in a similar circumstance and then customized, as needed, for  each student’s particular circumstance.  [Guidance issued 8/26/2011]

ACP-Q4:  Must the academic plan be mathematically set to graduate the student within the  150% time frame?
ACP-A4: Under the regulations at 34 CFR 668.34(c)(3)(iii)(B) and  668.34(d)(2)(iii)(B), the academic plan must be designed to ensure that the  student is able to meet the institution's satisfactory academic progress  standards by a specific point in time.   In some cases, this could mean that the maximum timeframe would be  extended based on the student's approved appeal.  [Guidance issued  8/26/2011]

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