Pop Quiz – Are Schools Required to Check Satisfactory Academic Progress After the Second Academic Year?


The school had the same satisfactory academic progress (SAP) policy for a long time, but recently hired a new Director of Financial Aid. The director reviewed the institution's policies and procedures but did not see where the school evaluated students at the end of the second academic year to ensure students have academic standing consistent with the school's graduation requirements. Is this a required review?


Yes.  See the following from the U.S. Department of Education(ED)'s Program Integrity Q&A, Satisfactory Academic Progress (emphasis added):

“R-Q2: How does the qualitative portion of a SAP review relate to the requirement for a student to have a GPA of at least 2.0, or academic standing consistent with the institution's requirements for graduation?

R-A2: An institution's SAP policy is required to include the GPA (or equivalent) a student must achieve at each evaluation to be considered as making satisfactory academic progress.  This qualitative standard must be reviewed at each evaluation of the student's progress.

In addition, the Higher Education Act requires a specific qualitative review at the end of the student's second academic year.  In this context, we have interpreted the “second academic year” as the student being at the school for 4 semesters or 6 quarters, regardless of a student's enrollment status.  At that point, the student must have a GPA of at least a 2.0 or its equivalent or have academic standing consistent with the institution's graduation requirements. [Guidance issued 8/26/2011]”

This means, although a school may evaluate students either at the end of each term or annually, it must also review of students at the end of students' second academic year as defined by ED. This may not follow the established review cycle but must still be done to remain in compliance with statute and 34 CFR 668.34(a)(4)(ii).

Student Aid Index:

For additional information, try NASFAA's Student Aid Index. It is a central hub of all the important financial aid resources you need with direct links to legislation, regulation, Dear Colleague Letters, and other ED and NASFAA references. It is updated on a rolling basis with the latest news and changes. Search Satisfactory Academic Progress.

Test your financial aid knowledge with past pop quizzes based on real scenarios from financial aid offices on our Pop Quizzes page.


Publication Date: 9/24/2020

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