[Oasfaa] SAP Regulatory Question

[Matt D. McCoin]

I have a question regarding the quantitative portion of the SAP policy.
I had an outside agency explain a different interpretation than what I
have understood it to be. The question is regarding the following
regulation:

 

34 CFR (e) For purposes of determining student eligibility for
assistance under a Title IV, HEA program, establishes, publishes, and
applies reasonable standards for measuring whether an otherwise eligible
student is maintaining satisfactory progress in his or her educational
program. The Secretary considers an institution's standards to be
reasonable if the standards-

 

(ii) A quantitative component that consists of a maximum timeframe in
which a student must complete his or her educational program. The
timeframe must-

 

A)      For an undergraduate program, be no longer than 150 percent of
the published length of the educational program measured in academic
years, terms, credit hours attempted, clock hours completed, etc. as
appropriate. 

 

The question surrounds transfer students and how their academic history
at other institutions would impact the quantitative component of their
SAP. The outside agency is stating that a school is only required to
look at this reg through the lens of the particular program the student
is enrolled in at that school; therefore, all other attempted coursework
at other schools would not be included in calculating whether or not a
student would reach 150% of the attempted hours for the school's program

 

This does not seem consistent with the qualitative component which
includes a cumulative G.P.A that looks at coursework from other schools.
If schools only look at the attempted hours for the program the student
is in at that particular school, what is to keep a student from
enrolling in multiple schools over multiple years and continue receiving
grants? The student may meet the qualitative requirements (ie, they
withdrawal before receiving a negative grade), but if schools are not
required to look at attempted coursework at other institutions, how
would the school ensure that the student is meeting the quantitative
component of SAP?  If the reg is intended to make sure the student is
progressing until completion of the degree, why would it be set up that
there is no accountability for a transfer student to meet the
quantitative component of SAP?

 

I would like to get your understanding of this regulation. Thanks.  

 

Matthew D. McCoin

Director of Financial Aid

St. Gregory's University

(405) 878-5396

 

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