Verification and Satisfactory Academic Progress

Jamie MaloneMarty Guthrie

U.S. Department of Education

Today’s Agenda

• Resources

• Verification Regulations

• Federal Register Notice

• Satisfactory Academic Progress

• Dear Colleague Letter

• Questions?

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Resources

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

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Verification Regulations

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Verification

• Effective date delayed until July 1, 2012– 2012-13 award year

• Institutions may need time to make changes to their institutional processing systems

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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”

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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

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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

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Verification: General Changes

• Must complete verification prior to exercising professional judgment

• Codifies long-standing policy in regulations

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Verification: Selection

• Eliminates 30% limit• Department targeting error-prone items to

select applications to verify• Institutions must verify all applicants we

select

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Verification: Selection

• Institutions must continue to resolve conflicting information they believe is inaccurate

• Institutions keep flexibility to select additional information or applications for verification

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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

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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

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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

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Verification: Items to Verify

• Annual Federal Register notice– Items to verify– Documentation

• Initially, will include the current five data elements

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Verification: Documentation

• Specified as acceptable in annual Federal Register notice

• Retained current documentation requirements with technical changes

• Added option to retrieve electronic data from IRS

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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

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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

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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

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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

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Verification: Deadlines

• Require institutions to follow cash management procedures for Direct Loans

• Removed the requirement to pay Pell Grant on the higher EFC

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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

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Verifications: Corrections

• Removed $400 tolerance• Require all corrections over $25 to be

submitted• Require all corrections of nondollar items

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Federal Register Notice

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Federal Register Notice

• Published Spring/Summer 2011• Describes 2012-2013 verification items• Outlines acceptable documentation• Lists other verification resources

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Satisfactory Academic ProgressRegulations

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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)

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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

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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

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SAP: Policy Requirements

• GPA that a student must achieve at each evaluation (qualitative standard)

• Pace of progression at each evaluation (quantitative standard)

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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

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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

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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

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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

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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

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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

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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

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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

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SAP: Frequency of Review

• Regulations are organized by frequency of SAP evaluation—– At the end of each payment period, or – Less frequently

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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

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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

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SAP: Academic Plans

About academic plans—• Not regulated• General or specific• Flexibility to address student situation• Appeal needed to implement or change

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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

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SAP: Notifications

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

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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

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SAP Dear Colleague Letter

• Expected in summer 2011• Will include questions and answers clarifying

the SAP provisions in the 10/29/10 regulations

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Contact Information

We welcome your feedback. You may contact us at:

• Phone: 312-730-1528• Email: Jamie.Malone@ed.gov• Fax: 312-730-1520

• Phone: 202-219-7031• Email: Marty.Guthrie@ed.gov• Fax: 202-502-7874