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1.6.2 Satisfactory Academic Progress

A student must maintain satisfactory progress in the course of study in order to remain eligible for assistance.202 Schools must have a published policy for monitoring that progress. There are requirements describing how often a school must check satisfactory academic progress (SAP).

In general, for programs longer than two academic years, students must have a “C” average or its equivalent by the end of the second year (regardless of how many credits they have accrued) or have an academic standing consistent with the requirements for graduation.203

For programs of two years or less, schools must have a qualitative standard at least as stringent as described in the standards above.

There is also a quantitative standard. Otherwise, a student could, for example, maintain a high GPA by withdrawing from every course he or she attempts after the first year. This student would have a high GPA but would not be progressing towards graduation. The SAP therefore also includes a quantitative measure to determine the number or percentage of courses, credit hours, or clock hours completed.204

Schools must explain how they handle course repetitions and how students may appeal determinations that they are not making satisfactory academic progress.

In a False Claims Act case, former employees sued Kaplan University, alleging a number of violations of the program participation agreement, including manipulation of students’ academic progress. Although some of the claims survived, the employees’ failure to plead sufficient facts or show how the school violated the Higher Education Act led to the court’s dismissal of the claim involving the manipulation of students’ academic progress.205


  • 202 {170} 20 U.S.C. § 1091(a)(2), (c); 34 C.F.R. §§ 668.16(e), 668.32(f), 668.34.

  • 203 {171} 34 C.F.R. § 668.34.

  • 204 {172} 34 C.F.R. § 668.34(a)(5) (requiring that institution’s policy specify the pace at which the student must progress through the academic program), (b) (defining “maximum timeframe”).

  • 205 {173} Urquilla-Diaz v. Kaplan Univ., 780 F.3d 1039 (11th Cir. 2015). See also §, infra.