NASFAA AskRegs: How Do We Treat COVID-19 Related Withdrawals In Our SAP Calculation?

This AskRegs Knowledgebase Q&A was updated to include the latest guidance about the end date of the following COVID-19 waiver or flexibility in the June 14, 2023 Electronic Announcement (GENERAL-23-46).

COVID-19 related withdrawals are attempted credit hours or clock hours that the student was unable to complete, just like other withdrawals. Due to COVID-19, the difference in treatment relates only to the quantitative (pace) component of Title IV satisfactory academic progress (SAP). The same guidance applies to individual courses the student dropped (withdrew from) due to COVID-19.

Quantitative/Pace Component: Under Section 3509 of the CARES Act and the May 15, 2020 Electronic Announcement, for the quantitative (pace) evaluation of SAP, schools are allowed (not required) to exclude any attempted credits a student was unable to complete as a result of the COVID-19 public health emergency. This includes all COVID-19 related withdrawals (or drops) during the payment period or period of enrollment for which the SAP evaluation is taking place. This flexibility applies for SAP evaluations made through the end of the payment period that includes the last date of the national emergency. Since the COVID-19 public health emergency ended on May 11, 2023, the flexibility applies through the end of the payment period that contains May 11 at the school. The COVID-related course withdrawals would continue to be excluded cumulatively in future SAP evaluations even after May 11, 2023. In the June 14, 2023 Electronic Announcement (GENERAL-23-46), the U.S. Department of Education (ED) stated, "Beginning with the following payment period, schools must comply with normal SAP requirements. Schools may continue to approve student appeals based on COVID-19-related circumstances on a case-by-case basis based on normal SAP authority."

The student is not required to submit a SAP appeal for the school to exclude the COVID-related withdrawal from the quantitative evaluation. However, to exclude the attempted credits from SAP, the school must have reasonably determined that the student’s failure to complete those credits was the result of a COVID-19 related circumstance. Allowable circumstances include, but are not limited to:

Illness of the student or family member;
Need to become a caregiver or first responder;
Economic hardship;
Added work hours;
Loss of childcare;
Inability to continue with classes via distance education; and
Inability to access wi-fi due to closed facilities.

If the school temporarily ceases operations during the payment period or period of enrollment being evaluated for SAP, the school can exclude all attempted credits from the SAP evaluation for all COVID-related withdrawals during that payment period/period of enrollment. In addition, the R2T4 guidance in the May 15th announcement allows schools to assume a student was a COVID-19 related withdrawal if the school moves students from ground-based instruction to distance learning, closes campus housing or other campus facilities, or experiences other interruptions in instruction. It is NASFAA's understanding that, if this is a reasonable determination for R2T4 purposes, it can be a reasonable determination for SAP purposes; however, what is a reasonable determination is left to the school.

If in doubt, collect an attestation from the student. It can be a simple statement or form on the student’s portal in which the student indicates he, she, or they were impacted by COVID-19 and allowing them to explain why. Or, you could amend your SAP appeals communication to include such a statement without requiring a full-blown SAP appeal. How you collect the attestation is up to the school.

Whether you choose to exclude some or all courses that are COVID-related withdrawals is up to the school. That said, we're not sure why you would treat some COVID-related course withdrawals differently than others. Whatever your reasons, be sure to document them in your SAP policies and procedures. You also will need to adjust your systems accordingly.

The May 15th announcement provides this example to assist with the pace calculation:

"Regarding the effect of excluding attempted credits on maximum timeframe, SAP regulations require that the pace at which students progresses through the program ensures completion of that program within the maximum timeframe. A four-year program consisting of 120 credit hours with a maximum timeframe of 180 credit hours (150 percent of program length) must have a pace of 66.666 percent (rounded to 67 percent), cumulatively measured at each interval, to ensure students complete within maximum timeframe. For example, the pace of a student who has completed 78 of 120 attempted hours is 65 percent (78/120), below what is necessary to be making SAP. However, if 12 credits the student attempted but was unable to complete in spring of 2020 are excluded due to a COVID-19 related circumstance, the pace becomes 72 percent (79/108) and he or she is making SAP. The 12 credits are effectively excluded from the maximum timeframe as well as the measurement of pace."

Qualitative/GPA Component: The answer is different, and the above flexibility does not apply to the qualitative measure of SAP (usually a grade point average--GPA). Lacking guidance from ED to the contrary, the Title IV regulations remain in place for the qualitative measurement. Under 34 CFR 668.34(a)(6), schools have long had the ability to determine how to treat withdrawals in the qualitative evaluation of SAP, with one exception. Under 668.34(a)(1), calculation of a student's GPA for Title IV SAP purposes must be at least as strict as the calculation of the GPA for academic purposes at the institution. Otherwise, it is up to the institution to establish a policy on how it treats withdrawal grades. In other words, the school can choose to ignore "W" grades or assign other non-letter grades that cause the course to be excluded from the GPA calculation. The school can also assign letter grades or treat them as "0" grade points in the SAP calculation. See Volume 1, Chapter 1 of the FSA Handbook.

Whether or not the school chooses to ignore "W" grades or assigns non-letter grades that are excluded from the SAP calculation will determine if a SAP appeal is required for the qualitative component. If the school assigns a "W" or other non-letter grade, and the school excludes those courses from the GPA calculation, a SAP appeal would not be required for the qualitative component. Otherwise, if the grade that is assigned to the course will impact the calculation of the GPA, a SAP appeal still is required for the qualitative component, even when it is not required for the pace calculation noted above.

When a student is required to appeal a SAP determination of the qualitative component due to COVID-19, the March 5, 2020 Electronic Announcement states, "An institution’s SAP appeal policy (34 CFR § 668.34(a)(9)) must, among other things, describe the basis on which a student may file an appeal: the death of a relative, an injury or illness of the student, or other special circumstances. Circumstances related to an outbreak of COVID-19, including, but not limited to, the illness of a student or family member, compliance with a quarantine period, or the general disruption resulting from such an outbreak may form the basis of a student’s SAP appeal even if not specifically articulated in the institution’s SAP policy."