Pop Quiz - Does Every Student Need to Be Evaluated for SAP Using the Same Standards?


A school may have students come back and complete multiple programs. For example, Student A completes a program in medical coding, then comes back and completes a program in radiology. Student B completes a program in phlebotomy, then returns to complete a program in medical coding. When evaluating satisfactory academic progress (SAP), does every student need to be evaluated using the same standards or is it programmatic?


The evaluation of SAP is based upon program. See the following from the ED Program Integrity Q&A:

"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]"

Also see 34 CFR 668.34(a) [emphasis added]:

"(a) Satisfactory academic progress policy. An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the title IV, HEA programs…”


Publication Date: 3/18/2016

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