Don’t Be a Sap, Know Your SAP! And Other Recent Audit Topics Presented by Robert Helgeson Audit Manager for the Office of Higher Education
Agenda SAP Policy Issues and Best Practices • Tax Filing Discrepancies • Timely and Accurate Reporting to OHE • Summary • Resources & References • Don’t Be a Sap, Know Your SAP! | www.ohe.state.mn.us
SAP Policy • OHE has adopted the U.S. Department of Education’s (ED’s) requirements which became effective July 1, 2011 . • When we refer to Title IV aid this also refers to MN State Aid Programs with the exception of SELF. • Electronic Code of Federal Regulations: §668.34 Satisfactory Academic Progress • (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 education program and may receive assistance under Title IV, HEA programs. • In July 2019, the ED’s Office of the Inspector General (OIG) released a report detailing issues with the Office of Federal Student Aid's (FSA) oversight of institutions' compliance with SAP regulations. (Referenced later in the presentation). • FSA included SAP-related issues in its list of the top 10 program review findings from 2013 through 2018. Don’t Be a Sap, Know Your SAP! | www.ohe.state.mn.us
SAP Policy 1. At least as strict as the policy applied to a student not receiving financial aid under the Title IV, HEA programs. 2. Must be consistently applied to all students within categories of students. • e.g. FT, PT, undergraduate, graduate, and educational programs. 3. Measurement of student’s progress at each evaluation: • Policy must require evaluation at the end of each payment period for students in programs lasting one year or less. • For all other programs, a policy must require, at a minimum, annual reviews and must occur at the end of a payment period. Don’t Be a Sap, Know Your SAP! | www.ohe.state.mn.us
SAP Policy 4. Qualitative – Must specify the grade point average (GPA), or comparable equivalent, that a student must achieve at each evaluation. • For student’s enrolled in a program of more than two years, the policy specifies that at the end of the second academic year, the student must have a GPA of at least a “C” or its equivalent, or have academic standing consistent with the institution's requirements for graduation. • For example, if the school uses a 4.0 scale, a 2.0 would be required. • In addition, the HEA requires a specific qualitative review at the end of the student’s second academic year. • Second year is interpreted as the student being in school for four semesters or six quarters, regardless of a student’s enrollment status. • At that point, the student must have a GPA of at least a 2.0 or it’s equivalent or have academic standing consistent with the institution’s graduation requirements. Don’t Be a Sap, Know Your SAP! | www.ohe.state.mn.us
SAP Policy 5. Quantitative - Must specify the pace at which a student must progress through their educational program to ensure that the student will complete the program within the maximum timeframe. • A student is ineligible via the max timeframe element when it becomes mathematically impossible for them to complete their program within 150% of its length. • Max Timeframe: For undergraduate programs, a period of no more that 150% of the published length of the program. For graduate programs, a period the school defines that is based on the length of the program. • Policy must clarify how a school will treat a student who changes majors or programs for SAP and max timeframe purposes. Don’t Be a Sap, Know Your SAP! | www.ohe.state.mn.us
SAP Policy 6. Policy describes how student’s GPA and pace are affected by incompletes, withdrawals, repetitions, or transfer of credits. • Transfer credits that are accepted toward the student's educational program must count as both attempted and completed hours. • Must include number of allowed repeats on passed and failed classes. • School’s policy must have some means of assessing a student’s academic progress in remedial coursework. Policy may include ESL requirements and affect on SAP. 7. At the time of each evaluation, a student who is not meeting SAP, is no longer eligible to receive assistance under the Title IV, HEA programs. • Schools SAP policy must distinguish between its academic progress policies and financial aid progress requirements. Don’t Be a Sap, Know Your SAP! | www.ohe.state.mn.us
SAP Policy 8. Definitions of Warning, Probation, and Academic Plan • Warning: Status assigned to a student who fails to make SAP at an institution that evaluates SAP at the end of each payment period. • Student may continue to receive Title IV aid for one payment period without a student appeal. • Probation: Status assigned to a student failing to make SAP, who successfully appealed, and has had eligibility for Title IV aid reinstated for one payment period only. • Students are not allowed more than one probation period consecutively (one convoluted exception). • “Continued Probation” status no longer allowed in policy or in practice but is allowed in discussion with students. • Academic Plan: Regulations do not specify what needs to be included. The school and student must develop a plan that ensures that the student is able to meet the school’s SAP standards by a specific time (which may be graduation). Don’t be a sap, know your SAP! | www.ohe.state.mn.us
SAP Policy 9. Institution’s policy must specify the conditions under which a student may appeal and the process for doing so, including: • How the student may reestablish eligibility for financial aid. • The circumstances for which a student may submit an appeal. • Information the student must submit related to why the student failed to make SAP, and what has changed that will allow the student to make SAP at the next evaluation. 10. If the institution doesn’t allow appeals, the policy must describe how the student may reestablish his or her eligibility to receive assistance under the Title IV, HEA programs. • taking time off or paying your own way cannot reestablish eligibility Don’t be a sap, know your SAP! | www.ohe.state.mn.us
Tax Discrepancies Disclaimer – The staff at OHE are not qualified to provide legal or tax advice • The federal 2019-20 Application and Verification Guide states that FAAs are required to know: (1) whether a person was required to file a tax return, (2) what the correct filing status for a person should be, and (3) that an individual cannot be claimed as an exemption by more than one person. • The Guide goes on to suggest FAAs use IRS Pub. 17 “Your Federal Income Tax For Individuals” as a resource and provides the page numbers to refer to. Don’t Be a Sap, Know Your SAP! | www.ohe.state.mn.us
Tax Discrepancies When conflicting information is not correctly resolved, the result is an invalid ISIR. Without a valid ISIR, OHE may require the return of any Minnesota aid disbursed to a student. • Schools may choose to act when: There is a presence of one or more ISIR Comment Codes 361-368 but ISIR is not selected for verification, or • there are no other documents with conflicting information. • Schools must act: If the ISIR is selected for verification with or without ISIR Codes 361-368. While tax filing status and marital • status are not verifiable items, once a school has additional tax and other information, then it must resolve conflicting data. When performing a professional judgment (PJ) on an ISIR selected for verification a school must complete • verification, resolve conflicting information, submit changes to CPS, and obtain a new ISIR before performing the PJ. • Regardless of verification status, a school that has additional information provided to it by a student/family must resolve any conflicting information, even if the school did not request the additional information. Don’t Be a Sap, Know Your SAP! | www.ohe.state.mn.us
Tax Discrepancies Discrepant Tax Data The following is an excerpt from the Federal Application and Verification Guide for 2019-20: • “Financial aid administrators do not need to be tax experts, yet there are some issues that even a layperson with basic tax law information can evaluate. Because conflicting data often involve such information, FAAs must have a fundamental understanding of relevant tax issues that can considerably affect the need analysis. You are obligated to know: (1) whether a person was required to file a tax return, (2) what the correct filing status for a person should be, and (3) that an individual cannot be claimed as an exemption by more than one person.” (emphasis added by OHE) Don’t Be a Sap, Know Your SAP! | www.ohe.state.mn.us
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