Posted Date: June 6, 2011

Author:  David Bergeron, Deputy Assistant Secretary for Policy, Planning and Innovation, Office of Postsecondary Education

Subject: Satisfactory Academic Progress Reviews for Students in Clock Hour Programs

On October 29, 2010, the Department published in the Federal Register final regulations on several program integrity issues. These regulations are (except for the new verification rules) effective July 1, 2011. Over the past several weeks we have posted to our IFAP website several Dear Colleague Letters providing information and guidance on some of the new regulatory changes. While we are in the process of preparing additional Dear Colleague Letters on other topics of the October 29, 2010 regulations, we provide the following guidance related to satisfactory academic progress (SAP) reviews for students in clock hour programs.

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 may review a student’s academic progress in a program at the end of each 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:

  1. At the point when the student’s scheduled clock hours for the payment period have elapsed, regardless of whether the student attended them; or
  1. At the point when the student has attended the scheduled clock hours; or
  1. 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 Section 668.34(a)(5)) and maximum timeframe (in Section 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 Section 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.

   

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