Dear Camille,
Monday morning, you requested responses from many administrators to questions related to the Course Program of Study (CPoS) regulation. I am providing a response to the various questions on behalf of the administration. (The other administrators who were contacted have read and contributed to these responses.)
I have not answered questions related to the numbers of students affected and costs of software additions because the administration does not wish to risk identifying the small number of students affected, and it is general practice not to discuss the University’s finances.
In addition, many members of the administration will meet on Dec. 2 to discuss CPoS and its approach to helping students manage compliance with it. At that meeting, the administration will discuss potential changes to technology, curriculum, transcription of AP/IB and dual enrollment credits, and communications in response to the situation. Due to the complexity of tactics that might be pursued to respond to CPoS, it will take several meetings to determine a long-term approach. Until the University administrators meet to develop a long-term approach to the matter, I am unable to fully answer some of your questions.
Responses to the general issues raised:
When did the administration learn that there was an issue related to CPoS?
First and foremost, CPoS is a relatively new government regulation that affects access to federal and state aid, including federal subsidized loans, not a University policy. (For information about the background and applicability of CPoS, please see Sewanee’s Financial Aid webpage.) The core principle of CPoS is that the federal and State governments will not underwrite coursework that does not apply to degrees (programs of study). Sewanee’s initial understanding of this regulation was that all of our courses can potentially apply to one of three categories of degree requirements: general education, a major, and electives. For years, the State did not question Sewanee’s interpretation of the CPoS regulation.
In May 2024, the Tennessee Education Department began to conduct audits of institutions in higher education located in Tennessee for compliance with the federal regulation. At the end of that audit, the Tennessee Education Department found that we had a few individuals graduate in 2024 who were not in compliance with CPoS; they had received federal and/or State aid but had not taken 12 or more credit hours required for their degree in their final semester. In most of these cases, students had brought AP/IB or dual enrollment credits to Sewanee or had taken more than the standard 16-credit hour course load in one or more semesters. Discussions with the Tennessee Education Department auditors helped to clarify the State’s interpretation of CPoS, monitoring standards, and the enforcement procedures.
Through the early part of the summer, the University examined the records of students to devise a means of monitoring student compliance with CPoS. The State requires institutions to have monitoring systems for student compliance with CPoS. By July, the University had examined records of students using a mixture of software and personal reading of transcripts by staff members in the Financial Aid Office. In July, the Tennessee Education Department informed the University that its method of monitoring complied with State requirements. The University has implemented this procedure to identify students potentially affected by CPoS while it has explored the capacity of our software systems to produce reports that would have similar results.
During the early fall, several administrative offices collaborated in the reading of degree audits in SODA (Sewanee Online Degree Audit) to identify students who might fall out of compliance with CPoS in the Easter 2025 semester. Administrators also developed tools to help advisors and students to understand the federal regulation and how to navigate it. The Registrar began to have meetings with advisors in October in order to familiarize them with the regulation. These meetings were intended to facilitate advising on CPoS in the short term, while the administration continues to determine a long term approach to the regulation.
What institutions have been affected by this regulation?
CPoS is a federal regulation that affects both federal and state aid. Consequently, all U.S. institutions of higher education are affected by this regulation and must comply with it. At the same time, State authorities are agents of enforcement based on their administration of state aid, and states appear to vary significantly in their approach to enforcement and, perhaps, interpretation. For example, many schools in Tennessee and other parts of the Southeast have recently adopted statements related to CPoS, which signals a change in enforcement or interpretation has occurred. Other liberal arts colleges in Tennessee and other areas of the country are affected by CPoS. Colleges and universities in other parts of the country have published statements on how students should comply with CPoS, but there appears to be a greater concentration in the Southeast, which suggests variance in regional implementation.
A technological solution to the problem?
The University has requested proposals from vendors to assist with adding to our software system for monitoring progress toward degrees, DegreeWorks, to have a technological solution for monitoring student compliance with CPoS. The University plans to contract such a vendor to carry out the required updates. The vendor requires 6-9 months to complete the work, which requires inputting all of the catalog’s courses, academic rules, and the complex logic structure into DegreeWorks. The long period of time necessary to complete this task by a vendor that has provided services to other similar colleges and universities indicates the complexity of the work. The University is committed to adopting software additions to assist students with monitoring their financial aid and progress toward their degrees, so that they can ensure compliance with CPoS.
Changes to curriculum?
While the administration and faculty will explore potential changes to the curriculum to assist students, curricular changes may provide limited solutions and could generate new problems. For example, increasing or changing graduation requirements to assist students with CPoS might cause other students who do not meet those standards to be unable to graduate. For this reason, the administration and faculty will have to tread carefully in considering curricular changes. The issue of compliance with CPoS is not just the mixture of classes but the number of credit hours required to graduate. Altering the types of classes that students must take without increasing the number of credit hours required would have the effect of reducing the number of elective credits students may pursue. As a consequence, flexibility would be lost within the curriculum.
Punishing students?
CPoS is a federal regulation, enforced by state and federal agencies, that requires compliance by colleges and universities. Sewanee, like other institutions of higher education, must comply with the regulation. Each year, the University receives federal and state aid to allocate to students who meet the eligibility criteria. The University will not receive aid from federal and state authorities for those students who do not comply with CPoS rules, so the University’s following CPoS restrictions is not a case of denying aid to students. It is important for students to monitor their compliance with CPoS to avoid future loss of federal and State aid. The administration sympathizes with students who were found to be out of compliance with the regulation, but in administering the federal regulation it is in no way acting to punish students. When it was discovered that some seniors were unexpectedly facing their final semester without eligibility for federal and state grants, the University took swift action to minimize the financial burden on these students. In a demonstration of care and commitment, the University replaced the lost federal and state grants with institutional aid to support their successful completion of their studies. The University continues to explore loans for students who face loss of federal subsidized loans.