Brief: SAP Requirements Create Barriers to Underserved Students

By Maria Carrasco, NASFAA Staff Reporter

A new policy brief out of Higher Learning Advocates argues that satisfactory academic progress (SAP) requirements disproportionately impact low-income students and students of color, leaving many without federal financial aid and without ever completing a degree or credential.  

The brief examines how current SAP policies can be confusing for many students, such as those who are new to college and arrive academically underprepared, do not receive proper advising, or face unexpected life challenges.

Institutions can create their own SAP requirements, but at minimum students must maintain at least a 2.0 GPA and pass enough classes to graduate within 150% of the expected timeframe in order to receive federal student aid.

While SAP requirements served a purpose 47 years ago, when it was first established, the brief shows that it now disproportionately impacts Black, Hispanic, and Indigenous American students, who failed to meet SAP more than twice the rate of their white peers. Among those students who failed to meet SAP standards, roughly 77% were students from low-income backgrounds who lost their Pell Grant award, the brief notes.

“Losing access to critical financial aid due to not meeting SAP requirements can prevent students from staying in school, especially the 6.7 million Pell Grant recipients who rely on this aid to access higher learning and returning adults seeking a competitive advantage in the labor market,” the report states. 

That leads to many students being “SAP-ed out” of higher education, which according to the brief is when a school denies a student’s SAP appeal. The brief notes that out of the fear of being audited by the federal government and losing an institution’s ability to distribute federal financial aid, some financial aid administrators are “conservative” in applying the “special circumstances” component of the SAP rule. 

Being “SAP-ed out” is particularly tough for returning adult learners, who may have stopped out or dropped out and want to return to school. As the brief notes, there are currently over 39 million adults in the U.S. who have some postsecondary academic credit, but no credential and are not currently enrolled in higher education. 

“These students face challenges that may affect their academic performance, such as trouble securing stable and affordable child care, job loss, financial duress, or other circumstances outside their control,” the brief states. “Once these students have a chance to get back on their feet and are ready to finish their education, they should be able to return to school without having to jump through unnecessary hoops.”

The brief highlights actions that have been taken at the state level to get returning adult learners back into higher education, including Indiana,  which has an Adult Student Grant and a Workforce ReadyGrant. The grant programs allow ​​returning Indiana students not enrolled during the previous two years to become automatically eligible for federal student aid even if they “SAP-ed out.” 

At Cuyahoga Community College in Cleveland, Ohio, the college implemented several steps to help students with SAP. Students are notified of their SAP status every term instead of annually and operate a fully-online SAP appeals process. Additionally, the college’s SAP appeals review committee is composed of campus administrators including the financial aid director, enrollment services director, and dean of academic counseling. And students are able to re-submit a SAP appeal during the same term. 

The brief also outlines several solutions the federal government can take to ensure that underserved students are able to maintain their federal student aid. According to the brief, the policy should be updated to automatically reset students’ SAP standing after two years of non-enrollment, and there should be clarified guidance on school’s flexibility to create their own automatic SAP reset period.

Institutions should also be required to collect and report data on the impact of maintaining SAP on their own campus, so institutions can better align their SAP policies to meet the needs of their students. Additionally the term “special circumstance” should be clearly defined, but  schools should also note that “any published list of circumstances is not exhaustive and that there could be other valid reasons for an appeal.”

“Improved guidance should empower financial aid administrators who assess and approve SAP appeals to use their flexibility with professional judgment to make way for students who previously did not meet SAP requirements based on circumstances outside of personal illness or the death of a family member,” the brief states. 


Publication Date: 5/1/2023

Yolanda T | 5/8/2023 11:42:30 AM

An automatic reset after 2 years...... Definitely do not agree with. SAP standards and the current opportunity for a student to appeal mitigating circumstances and be placed on probation status is very flexible with the current policies, procedures, and federal guidance.

Jesse H | 5/1/2023 5:21:41 PM

According to another recent policy brief, 97% of the drownings that occur in the ocean take place because it is composed almost entirely of water. This has an especially disproportionate and unfair impact on sailors and beachgoers who are unable to swim.

"It seems unreasonable that in addition to the extreme danger to seagoers from this excessive amount of H2O, the fact that it takes up about 70% of the earth's surface represents an unfair and unequitable use of the planet's real estate.," said the lead researcher, Belabor D. Obvious. "We recommend pulling the bathtub drain at the bottom of the Mariana Trench to gradually rectify this problem and make the area currently occupied by the Pacific, Atlantic, and Indian Oceans into a smaller and more manageable body of water that better serves the needs of modern seagoers."


Now that I got my snark out of the way, I wholeheartedly endorse Helen F.'s compassionate and beautifully-stated point: having academic standards is not the problem. The real problem is all of the other ways society disproportionately makes life hard on disadvantaged students and makes it tougher for them to maintain SAP. Affordable daycare would do more to help these students than all the SAP leniency in the world.

On top of that, with LEU being limited and student indebtedness being such issues, allowing students to dig themselves neck-deep in a hole filled with Ws, Fs, and student debt with nothing to show for it is the greater evil by far.

Kimberly L | 5/1/2023 2:48:24 PM

While well intended, I don't think it is a problem asking for a C-average. Perhaps the issue is with communicating expectations BEFORE one registers and or attends classes.

Matt F | 5/1/2023 2:23:59 PM

You don't fix the success rate of students by changing the SAP standards. As others have noted there SAP is just revealing the systemic inequities in our society, not creating them. Messing around with the SAP standards doesn't solve anything.

Robert W | 5/1/2023 1:47:02 PM

We, through our elected Federal officials, are spending more money each year than we are collecting. Somebody will have to pay for these deficits down the line. If we do not improve our financial and budget management as a country, we run the risk of losing our status of the U.S. Dollar being the worlds reserve currency and a few countries would love for this to happen. Our debt could be lowered to junk status makeing it very difficult and expensive to finance.

It is my understanding prior to SAP requirements there were colleges, and some of them were public institutions, that were not to concerned about the success of students and were more concerned about enrolling everyone they could that could pay tuition and fees.

When online classes were invented some students would stay at a low cost school until they could no longer enroll due to SAP and start all over at another school. I never will forget those days.

Everyone does not need a college degree to earn a good living. I am no spring chicken, and in all my years I have never seen job availability like we are currently experiencing and with the World is Flat theory working in reverse now it should continue, unless there is a black swan event.

Tax payers, as we all are, are stakeholders in FSA and its success.

Finally, I would have liked to see the results of the study disclosed in this article for Asian American and students who are, or whose parents are naturalized citizens or in this country legally or illegally.

Many colleges now have private donor funds specifically earmarked for a student close to graduation and maxed out on FSA. I worked at one. The Georgia State model is being replicated across the land.

Finally, a student may appeal. I erred on the side of approving rather than denying in my younger days.

Random thoughts and memories of a semi-retired financial aid professional. These are my thoughts and I respect everyone elses.


Bob W

Aesha E | 5/1/2023 12:59:45 PM

Always disheartening when fellow FAAs are more concerned about taxpayer dollars than advocating for change that helps students.

I agree with Helen that SAP is an indicator, not the source, of a problem. I believe I've heard that SAP was implemented in the early 80s (maybe earlier, alluded to in the HEA of 1965). But the cost of education, expectations and demands of students, governmental policy and regulation (not necessarily directly associated with financial aid), and society in general have changed substantially in that time, all of which impacts a student's success. Where a student might once have been able to complete a degree at the nearby public college with the assistance of Pell and the earnings of a summer job--thereby allowing them to spend a greater proportion of their time attending to their coursework--that's a thing of the past. And that's only one of myriad things that may impact a student's success. (I mean... anyone remember the worldwide pandemic that started in 2020?...)

All this is to say we should work to advocate for change that recommits to the notion of a college education being a public good, and allow students to focus more on their studies than having to have a full-time job with college as a side goal. Increasing Pell, expanding SNAP benefits, improving or providing scholarship eligibility for part-time students, and improving state support of higher education are low-hanging fruit that could potentially improve performance and completion.

Sarah F | 5/1/2023 11:59:40 AM

SAP standards are generally set so that the student will complete their degree with at least a C average within 150% of the required credits needed to complete the degree. If a student can't do that, they shouldn't be able to continue utilizing federal aid. Think about lifetime aid limits. If we continue to allow students who are not on the right track to take out Pell, they will run out of Pell before they are done and be "Pelled-out" of school. In my experience, many of the students using Pell are also using loans. So now, there's a student who can't attend because they have maxed out their aid; they still have no degree and could have thousands of dollars more in debt than if they were "SAP-ed out". If someone is in a situation where they cannot be successful in school, it's in their best interest that they wait until they are in a position to be successful, rather than continuing to use up their eligibility. I worked at a school who was very lenient with their SAP policies and appeal approvals. As a result, there were many times I had to tell students who weren't close to graduating that they were maxed out. I agree that Helen F that this is a symptom of a larger systemic issue, but the solution is not throwing more money at it.

Donna W | 5/1/2023 11:40:47 AM

Why should any students not making SAP continue to receive funding if they do not make satisfactory academic progress? Would that not be wasting taxpayers' money??? Rewarding bad academic behavior? We have a standard that all students need to follow. What justifications are there for different student populations? Isn't that very subjective?

Austin M | 5/1/2023 11:3:01 AM

Satire? Or have we completely lost the plot?

Helen F | 5/1/2023 9:50:32 AM

The SAP inequities simply expose the impact of multiple systemic inequities that overwhelmingly harm our most vulnerable students. A student aid system that falls fall short of meeting low-income students' basic needs for survival, the resource contraints of access institutions serving the very students best positioned to transform their lives through education, the stunning disparities in the K-12 system, and the lack of social safety nets to keep children and families out of poverty--all of these factors contribute to poor SAP outcomes. SAP isn't the root of the problem--it's one of many metrics (CDR=another) that expose deeper systemic problems.

Courtney R | 5/1/2023 9:15:20 AM

I like that people are thinking about this! I do wonder how the programming would work for people who have a SAP 'reset'. Seems logistically tough, but definitely worth the work for these students!

Colby S | 5/1/2023 8:59:50 AM

“The grant programs allow ​​returning Indiana students not enrolled during the previous two years to become automatically eligible for federal student aid even if they ‘SAP-ed out.’”

Clarification is needed here. Independent students who are SAP terminated are eligible for the Adult Student Grant and Workforce Ready Grant in Indiana if they have not been enrolled in the last two years. This state aid exception to SAP does not impact federal student aid eligibility.

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