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Verification and Satisfactory Academic Progress . Jamie Malone Marty Guthrie U.S. Department of Education. Today’s Agenda. Resources Verification Regulations Federal Register Notice Satisfactory Academic Progress Dear Colleague Letter Questions?. Resources. For information, consult:

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verification and satisfactory academic progress

Verification and Satisfactory Academic Progress

Jamie MaloneMarty GuthrieU.S. Department of Education

today s agenda
Today’s Agenda
  • Resources
  • Verification Regulations
  • Federal Register Notice
  • Satisfactory Academic Progress
  • Dear Colleague Letter
  • Questions?

For information, consult:

  • Notice of Proposed Rulemaking (NPRM), published 6/18/10
    • Describes all changes to current reg
  • Final Rule, published 10/29/10
    • Responds to comments and describes changes to NPRM
    • Not a comprehensive review of all reg changes
  • Effective date delayed until July 1, 2012
    • 2012-13 award year
  • Institutions may need time to make changes to their institutional processing systems
verification general changes
Verification: General Changes
  • Emphasizes updating requirements through change to subpart heading
  • Removes references to individual programs
  • Defines “subsidized student financial assistance programs” and “unsubsidized student financial assistance programs”
verification general changes7
Verification: General Changes
  • Subsidized—
    • Eligibility uses EFC
    • Verification applies
    • Pell Grant, FSEOG, FWS, Perkins, Direct Subsidized Loan
  • Unsubsidized—
    • Eligibility does not use EFC
    • Verification does not apply
    • TEACH Grant, Iraq & Afghanistan Service Grant, Direct Unsubsidized Loan, Direct PLUS Loan
verification general changes8
Verification: General Changes
  • Uses “FAFSA information” instead of “application”
  • Defines “specified year” as base year or year prior to base year
    • Allows for option of using income data from a different year
    • No plans to exercise this option at this time
verification general changes9
Verification: General Changes
  • Must complete verification prior to exercising professional judgment
  • Codifies long-standing policy in regulations
verification selection
Verification: Selection
  • Eliminates 30% limit
  • Department targeting error-prone items to select applications to verify
  • Institutions must verify all applicants we select
verification selection11
Verification: Selection
  • Institutions must continue to resolve conflicting information they believe is inaccurate
  • Institutions keep flexibility to select additional information or applications for verification
verification exclusions
Verification: Exclusions
  • Removes certain exclusions
  • Clarifies provisions applicable to—
    • Applicants
    • Parents of dependent applicants
    • Spouses of independent applicants
  • Lists specific situations when parent’s or spouse’s information is not subject to verification
verification updating
Verification: Updating
  • Applicant required to update all changes in dependency status throughout the award year, except changes resulting from a change in the applicant’s marital status
  • Applicant’s responsibility, not institution’s
verification updating14
Verification: Updating
  • FAA may require applicant to update marital status to address inequity or to reflect more accurately the applicant’s ability to pay
  • Documentation not required if the information has not changed during subsequent verification of household size and number in college
verification items to verify
Verification: Items to Verify
  • Annual FederalRegister notice
    • Items to verify
    • Documentation
  • Initially, will include the current five data elements
verification documentation
Verification: Documentation
  • Specified as acceptable in annual FederalRegister notice
  • Retained current documentation requirements with technical changes
  • Added option to retrieve electronic data from IRS
verification documentation17
Verification: Documentation
  • For applicants with tax filing extension
    • May require completed tax return when filed
    • Must re-verify AGI and taxes paid, when/if the tax return is submitted
verification documentation18
Verification: Documentation
  • Tax return not signed by the tax filer
    • Must be signed, typed, printed, or stamped by the tax preparer and
    • Contain the preparer’s SSN, EIN or PTIN
verification interim disbursements
Verification: Interim Disbursements
  • Technical and conforming changes
  • May make a disbursement after completing verification but prior to receiving a corrected valid SAR or valid ISIR if the changes would not change the amount of aid
verification interim disbursements20
Verification: Interim Disbursements
  • To avoid liability, must ensure necessary corrections are submitted to ED
  • Valid SAR or valid ISIR required before disbursement can be made for all Title IV programs
verification deadlines
Verification: Deadlines
  • Require institutions to follow cash management procedures for Direct Loans
  • Removed the requirement to pay Pell Grant on the higher EFC
verification fund recovery
Verification: Fund Recovery
  • Requires institutions to reimburse program account if disbursement made without receiving corrected valid SAR or ISIR
  • Requires recovery of overpayments that occur from interim disbursements for students employed under the FWS Program
verifications corrections
Verifications: Corrections
  • Removed $400 tolerance
  • Require all corrections over $25 to be submitted
  • Require all corrections of nondollar items
federal register notice25
Federal Register Notice
  • Published Spring/Summer 2011
  • Describes 2012-2013 verification items
  • Outlines acceptable documentation
  • Lists other verification resources
satisfactory academic progress
Satisfactory Academic Progress
  • Previously, SAP requirements and references were included in 3 regulatory sections
    • Administrative capability §668.16(e)
    • Student eligibility §668.32(f)
    • Satisfactory progress §668.34
  • Now all requirements are in §668.34 with cross references in §§668.16(e) and 668.32(f)
sap new regulations
SAP: New Regulations

New regulations provide—

  • Continued flexibility for institutions to establish their SAP policies
  • Additional flexibility for institutions that monitor SAP more often than annually
  • Definitions for “warning” and “probation”
  • In general, a student who is not making SAP is no longer eligible for Title IV aid
sap policy requirements
SAP: Policy Requirements

Specified in §668.34 and include—

  • Measurement of student’s progress at each evaluation—
    • Can take place each payment period, annually, or less often than each payment period
    • Must occur at the end of a payment period
sap policy requirements30
SAP: Policy Requirements
  • GPA that a student must achieve at each evaluation (qualitative standard)
  • Pace of progression at each evaluation (quantitative standard)
sap details on standards
SAP: Details on Standards
  • Qualitative standard: required GPA
    • For programs more than 2 academic years: at the end of 2 years, at least a 2.0 or academic standing consistent with requirements for graduation
  • Quantitative standard: pace at which a student must progress to complete within the maximum timeframe
    • Calculate by dividing cumulative successfully completed hours by cumulative hours attempted
sap policy requirements32
SAP: Policy Requirements
  • How student’s GPA and pace are affected by incompletes, withdrawals, repetitions, or transfers of credits
  • Must count transfer hours accepted toward completion of the student’s program as both hours attempted and hours completed
sap defined terms
SAP: Defined Terms
  • Must incorporate the terminology used in these regulations
  • Must explain terms and use consistently with these regulations
  • Must make sure conditions of each term are clear to students
sap defined terms34
SAP: Defined Terms

Defined Term: 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 may continue to receive Title IV aid for one payment period
  • No appeal necessary
sap defined terms35
SAP: Defined Terms

Defined Term: Financial Aid Probation

  • Status assigned by an institution to a student who fails to make SAP, who has appealed, and has had eligibility for Title IV aid reinstated
  • May impose conditions for student’s continued eligibility to receive Title IV aid
sap defined terms36
SAP: Defined Terms

Defined Term: Maximum timeframe

  • For an undergraduate program—basically 150% of the published length of the program
  • For a graduate program—a period defined by the institution that is based on the length of the educational program
sap defined terms37
SAP: Defined Terms

Defined Term: Appeal

  • Process by which a student who is not meeting an institution’s SAP policy petitions the institution for reconsideration of the student’s eligibility for Title IV aid
sap defined terms38
SAP: Defined Terms

Defined Term: Appeal (more)

  • Must specify the conditions under which a student may appeal including—
    • Why the student failed to make SAP; and
    • What has changed that will allow the student to make SAP at the next evaluation
sap frequency of review
SAP: Frequency of Review
  • Regulations are organized by frequency of SAP evaluation—
    • At the end of each payment period, or
    • Less frequently
sap payment period review
SAP: Payment Period Review

Evaluating at each payment period:

If student fails to make SAP, student—

  • Loses eligibility for Title IV aid
  • May be placed on Financial Aid Warning for one payment period
  • Must make SAP or may be placed on Financial Aid Probation after a successful appeal
sap payment period review41
SAP: Payment Period Review

Evaluating SAP each payment period (more)

  • After Financial Aid Probation, student—
    • Must be making SAP, or
    • Must be successfully following an academic plan
sap academic plans
SAP: Academic Plans

About academic plans—

  • Not regulated
  • General or specific
  • Flexibility to address student situation
  • Appeal needed to implement or change
sap annual review
SAP: Annual Review

Evaluating less frequently:

If student fails to make SAP, student—

  • Loses eligibility for Title IV aid
  • May be placed on Financial Aid Probation after an appeal
  • After Financial Aid Probation, must be making SAP or successfully following an academic plan
sap notifications
SAP: Notifications


  • Results of SAP review that impact the student’s eligibility for Title IV aid
  • Specific elements required to appeal SAP, if appeal process is used
  • Process for reestablishing eligibility for Title IV aid, if no appeal process is used
sap questions
SAP: Questions

People asked about…

  • Using different rates of assessment for different classes of students
  • Evaluating one factor at end of each payment period and another annually
  • Implementing SAP for the 2011 summer crossover payment period
sap dear colleague letter
SAP Dear Colleague Letter
  • Expected in summer 2011
  • Will include questions and answers clarifying the SAP provisions in the 10/29/10 regulations
contact information
Contact Information
  • We welcome your feedback. You may contact us at:
  • Phone: 312-730-1528
  • Email:
  • Fax: 312-730-1520
  • Phone: 202-219-7031
  • Email:
  • Fax: 202-502-7874