New Guidelines: CPoS Affects Students 

Camille Pfister
Editor-in-chief 

Over the past few weeks, some Sewanee students have had to completely restructure their college plan due to a change in interpretation of federal financial aid guidelines. Notifications about the change, sent out days before registration week, affected which classes students were registering for next semester and how they planned to complete majors to make sure they can still get federal and state financial aid. 

Impacted students are worried and upset at not having been told sooner. Said one student who asked for anonymity, “Apparently the school has known about this, but this is the first year they were actually getting in trouble for it.”

The federal guidelines, known as Course Program of Study or CPoS, requires students who receive federal financial aid to be enrolled in at least 12 credit hours of classes required for their majors in order to maintain the full amount of their aid awards. If a student has completed their major coursework, they may not be allowed to use that financial aid for electives or classes not required for graduation. In Tennessee, the state education agency requires students receiving state scholarships and financial aid to comply with CPoS. 

 The student newspaper at the The University of Tennessee at Knoxville, reported last spring that the state’s requirement was mandated by The Financial Aid Simplification for Tennesseeans or FAST Act, passed by the legislature in 2020. The Tennessee Department of Education told The Beacon that Tennessee colleges and universities should have implemented required changes to comply with the FAST act during the 2021-2022 academic year, as the state gave institutions enough time to prepare for them. “This incentivizes students to take courses within their program of study for faster completion and aligns payment of our state aid programs with federal financial aid programs,” the agency told the Beacon. 

In response to questions from The Sewanee Purple, Provost Scott Wilson issued a statement on behalf of senior administrators explaining that Tennessee’s department of education only recently began closely monitoring CPoS compliance.  

“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,” the administration’s response stated. “For years, the State did not question Sewanee’s interpretation of the CPoS regulation.”

But last May, the administrators’ statement indicated, the state audited Sewanee’s CPoS compliance. 

“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 (Advanced Placement or International Baccalaureate)  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.”

Administrators said the number of current Sewanee students at risk was “small” but they declined to give specifics.

Kelly Malone said she and other professors first heard about students potentially being impacted by CPoS requirements at a lunch for advisors on Oct. 9. It took until the end of October and the first week of November for faculty advisors and students to be told about potential financial aid cuts if they were found to be out of compliance. 

On Nov. 6, four days before registration began for spring classes, faculty advisors received lists of students who possibly needed to restructure majors or coursework. 

“Students have not personally brought this up to me and this is part of the problem—we as faculty don’t know which of our students are on financial aid,” Aaron Elrod, an economics professor at Sewanee, said. “I did bring up CPoS [in advisor meetings,] some students have heard of it and most haven’t heard of it. It’s difficult when you’re advising to start into that conversation of financial aid.”

On Nov. 8, Vice-Chancellor Rob Pearigen emailed faculty members an apology, expressing regret for the CPoS issue.  “This is not a matter that had my full attention until recently, and I’m still trying to better understand the policy, its timing and interpretation, and the full implications for our students and the University, both immediately and in the long term,” Pearigen wrote in the email, which a tenured professor shared with The Purple.  

Pearigen’s email said  the University is working on a “technological method through DegreeWorks”  to automate CPoS tracking. 

In their statement to The Purple, administrators declined to say how much such a software fix could cost because “it is general practice not to discuss the University’s finances.” 

Tennessee Tech’s website indicates that the institution has been monitoring each student’s CPoS requirements and guidelines with DegreeWorks since 2019. “While CPoS is not a new requirement, software enhancements became available for Tennessee Tech to begin actively monitoring at the start of the 2019 fall term,’ Tennessee Tech’s CPoS webpage states. “This is a requirement for any higher ed institution administering federal/state aid.” 

Likewise, Belmont University’s website indicates that the Nashville institution began tracking each degree-seeking student’s compliance “with new software integration”  in the fall of 2021. 

Sewanee students expressed frustration at having to scramble for information. One student, who prefers to remain anonymous, said she was at risk of losing all of her financial aid and wished “the school would come out with a statement” about what was happening to her and others. “I feel like there’s so much misinformation being spread and so much panic. It’s hard to figure out what to believe.” 

Most of the students affected took AP classes or dual enrollment in college-level classes during  high school.. “I came to Sewanee with a full year’s worth of credits,” one student said, adding that they are now having to figure out how to prolong what can they can claim as required coursework “so the government doesn’t have a reason not to fund me anymore.” 

“I feel like students who have been proactive in getting credits from high school, they’re gonna be the ones who are gonna deal with the most consequences. And I thought I was doing what I was supposed to, but it turned out the rules were being changed, and no one told us.” 

“It’s essentially punishing me for having transfer credits from dual enrollment, which sucks,” another student said.

Asked to respond, administrators wrote, “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.” 

One student said she will have to double major, which was not her original plan, and will have to put her preferred  major “on the back burner” so she doesn’t inadvertently complete its required coursework too soon – an accomplishment that  would take away  funding she  gets from the government.

This student said she also has not gotten any communication from Sewanee’s financial aid office, but her advisor emailed Registrar Beth Krager and Associate Dean of the College Alex Bruce and gave her their responses. “The fact that I’m only getting second hand information has not been helpful,” she said, adding that Krager and Bruce had been helpful and concerned. 

Elrod said faculty heard nothing for months after being told in May that Sewanee was not in compliance with CPoS for  the past fiscal year.. What happened between May and October, I don’t know..” 

In their statement University administrators said student records were examined for CPoS compliance – in some cases through individual transcript reviews –  in early summer, and in July, the state education agency informed the University that its monitoring met state requirements. In early fall, “several administrative offices collaborated” to identify students at risk, and in October,  the Registrar’s office began alerting advisors.

Administrators also told the Purple that The University is assisting current seniors to avert aid cuts. “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,” administrators said. 

Students say their advisors are working  hard to ensure affected students can stay in the University and continue to pursue their desired coursework. The administration met Dec. 2 to discuss “potential changes to technology, curriculum, transcription of AP/IB and dual enrollment credits, and communications in response to the situation,” the statement from the Provost said. 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.”

“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 administrators’ statement said. “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”.

Chloe Wright, Brendan Downes, and Tom Walker contributed to this story. 

To read the administration’s full response to the Purple’s questions, go to the Purple’s website.