The Federal Student Aid office released updated guidance in late March clarifying how clock-hour schools must evaluate Satisfactory Academic Progress for the 2025–26 award year. The update addresses several gray areas that had caused inconsistent program review findings over the past two cycles — particularly around mid-year transfer students and leave of absence re-entry.
What changed
The most significant update affects how schools calculate the pace of completion for students who take a leave of absence and return in the same payment period. Previously, guidance was silent on whether clock hours attempted during the pre-LOA segment should be included in the denominator. FSA has now confirmed they must be included, effective for evaluations conducted on or after July 1, 2025.
FSA also clarified the maximum timeframe calculation for programs that were shortened or modified mid-year due to accreditor approval of a curriculum change. Schools that reduced program length must recalculate maximum timeframe for all active students, not just new enrollees.
Who is affected
Any clock-hour program participating in Title IV — cosmetology, CDL, allied health, trade programs — needs to review its SAP policy language and evaluation procedures before the July 1 effective date. Schools using manual SAP tracking spreadsheets are at the highest risk of miscalculation.
What to do now
Review your SAP policy for language that explicitly addresses LOA re-entry and pace calculation. If your policy is silent, update it before your next evaluation cycle. If you use an SIS, confirm that it captures attempted hours at LOA exit, not just at the start of the leave. Document your interpretation in a policy memo dated before July 1.
Schools on Edudigital Cloud should note that SAP recalculation logic has been updated to reflect the new FSA guidance. No manual configuration is required — evaluations run after the June 15 platform update will use the revised calculation automatically.