Substantially Equal vs Not Substantially Equal Guidance

Overview

This page provides guidance to help users determine whether a program change (PC) should be processed as "Substantially Equal (SE)" or "Not Substantially Equal (NSE)" in Regent.  The information is a supplement to the Program Change Guidance for SBL data. 

The main thing to keep in mind is a Substantially Equal program change (SE PC) within an Academic Year (AY) will keep the student in the same AY as before the program change. The student continues the same AY in the new program. A program change that is Not Substantially Equal (NSE PC) will always start a new AY for the new program.

Notes:

  • Some schools may have additional policies regarding whether to process some program changes as NSE. Always refer to your school's internal policies.
  • An end user should never override a program change across different program structures (which is always NSE) to try to change it to an SE program change. The resulting academic plan structure would be unpredictable and Regent Award does not support this action.

Additional References

Table of Contents


SE and NSE Impact on Academic Years

In Regent, a Substantially Equal program change (SE PC) within an Academic Year (AY) will keep the student in the same AY as before the program change. The student continues the same AY in the new program. A program change that is Not Substantially Equal (NSE PC) will always start a new AY for the new program.

Overlapping AYs

Per ED regulations, Federal Subsidized and Unsubsidized loans have maximum amounts that are allowed per Academic Year; see Direct Loan Annual and Aggregate Limits. Those annual limits apply to all AYs and all loans within each loan's AY date range. For a NSE PC, Regent might create a new AY that has dates which overlap with the previous AY dates, which can affect the eligibility in the new AY. 

For term and nonstandard term programs, Regent can automate loan calculations for Subsidized and Unsubsidized loans in overlapping AYs. See Loan Automation for Overlapping Academic Years (OAYs).

Program Changes that Must Be Processed as NSE

Some program changes must be processed as Not Substantially Equal (NSE). Regent does not support processing those types of program changes as SE.

Different Program Types for Term, Nonstandard Term, and Nonterm

Students may change programs from a term or nonstandard term program, into a nonterm program; or vice versa. Those changes between different program structures must always be processed as Not Substantially Equal (NSE). An end user should never override a program change across program structures (always NSE) to try to change it to an SE program change. The resulting academic plan structure would be unpredictable and Regent does not support this action.

Different COD Attended Entity ID

If the 'COD Attended Entity ID' values are different for the two programs (i.e., at the Campus or Site level), the program change must be processed as NSE and cannot be overridden from NSE to SE.

  • If the Program Change is occurring across campuses or sites where the COD Attending ID differs, Regent considers the programs as NSE.  
    • The NSE determination cannot be overridden in the PMW by the user.
    • The purpose is to allow Regent Award to correctly handle student awards or loans such as during a campus-to-campus program change. 
      • The determinant on continuing Direct Loan awards at the new campus is whether or not the 'COD Attended Entity ID' is the same at both campuses. If the 'COD Attended Entity ID' is not the same at the new campus, the Direct Loan awards must be truncated at the old campus and new awards made at the new campus.
  • If the program change is occurring across campuses where the COD Attending ID are the same at the two campuses, then the programs may be considered SE by Regent Award by default, provided other constraints are met.
    •  This determination can still be overridden to NSE by the end user in the PMW.

General Guidance for SE Program Change Processing

In general, Regent supports the following Substantially Equal (SE) scenarios:

Term-Based – generally “SE” if:

  • Both programs use the same terms, and
  • Both programs define the AY with the same number of units and weeks.

Nonterm Based – generally “SE” if meet the rules in the Federal Student Aid Handbook for remaining in the same payment period:

  • The student is continuously enrolled at your school;
  • The coursework in the payment period the student is transferring out of is substantially similar to the coursework the student will be taking in the program into which he/she is transferring;
  • The payment periods are substantially equal in length in weeks of instruction and credit or clock-hours;
  • There are little or no changes in school charges associated with the payment period
  • The credits from the payment period the student is transferring out of are accepted for credit in the new program.

In addition to the above guidelines, the school ultimately determines whether a program change is occurring between "substantially equal" payment periods. Regent supports users processing Program Changes as SE or NSE, in order to accommodate different interpretations of "substantially equal" in the community.

When a Substantially Equal program change is completed within Regent Award, the student continues in the same academic year, same payment period, same loan period, etc. The total length of the program could change, but the Academic Plan structure would remain the same.

When the student is changing programs, and the two programs are substantially equal, but the program change is taking place between payment periods (either in the middle of the AY or between AYs), the following occurs: 

  • Mid-Year SE Change: Regent Award will leave the student in the same Academic Year.
    • The student will usually continue in the same Loan Period. However, Regent will reassess the grade level for term-based programs, which might result in a new loan period.
    • The total annual loan limits will still apply to the entire AY.
  • Between-AY SE Change: Because a change between AYs does not create an Overlapping Loan Limit scenario, awarding continues as normal for the new AY and new Loan Period.

Term-Based Program Changes

Regent Award supports program changes between terms or between Academic Years. Most term-to-term program changes may be processed as Substantially Equal (SE) in Regent. For term and nonstandard term program changes, the determination for whether a PC can be SE is whether the old and new programs both have terms of the same term length, the same AY length, and the same, non-overlapping dates for the terms. 

Term-based SE PCs

Term-Based PC – is is generally “SE” if:

  • Both programs use the same terms or have the same term dates
  • Both programs define the AY length with the same number of units and weeks 

If two term-based programs share the same set of terms or same term dates, and the same AY lengths, then a program change between those programs is usually Substantially Equal.

  • Term SE Example:  A SAY school has Fall, Spring, and Summer terms. A student graduates from a four-year undergraduate program at the end of the Fall term, and changes to a graduate MBA program in the Spring term. Because both programs have the same dates for Fall and Spring terms, the school would process the program change as Substantially Equal. The student would have a single Fall-Spring Academic Year. The student's financial aid, such as Federal Unsubsidized Loans, will be packaged in each term using the correct funds and limits for each program. The system will not exceed the total annual limits for the Academic Year. For Title IV aid, if the programs have different program levels (i.e. undergraduate and graduate), the student will also need two different ISIRs, one for each program. See Graduate and Undergraduate ISIRs.

A school may still choose to process a term-to-term Program Change as NSE even if the programs could be SE. For example, a school might have a policy that students who change from an Associate's degree to a Bachelor's program are considered Not Substantially Equal, even if both programs share the same terms and AY length. Regent would allow a user to process that program change as SE or as NSE.

Term-based NSE PCs

For NSE program changes, the system will create two separate Academic Years. When the new program is term-based, Regent can also automate loan calculations for overlapping AY dates. See Loan Automation for Overlapping Academic Years (OAYs).

If a student has a program change between two term-based programs that do not share the same set of terms, or the terms have different dates or overlapping dates or Academic Year lengths or types, then the program change must be processed as Not Substantially Equal (NSE).

  • Term-to-Term NSE Example:  A school has both BBAY and SAY programs. The BBAY programs use 18-week trimesters. The SAY programs use 12-week trimesters. A student changes from an undergraduate SAY Accounting program to an undergraduate BBAY Accounting program. Each program has a different set of terms with different start/end dates and different term lengths (18 weeks instead of 12 weeks). The school must process the Program Change as Not Substantially Equal (NSE).  

Additional Considerations

Regent does not support middle-of-term program changes between two programs within a term. For term and nonstandard term programs, students can have only one active program per term. For example, if a student starts Program A in Module 1 of the first week of the Fall term, that student cannot then change to Program B in Module 2 in the middle of the same Fall term. The student could only change to Program B at the start of the following term.

Regent supports manually processed Track Changes; see Track Change. If a student has a track change within a program, the new track usually starts a new AY. The new AY for the new track might overlap with the previous AY dates. If the new AY dates overlap, Regent can automate loan calculations for the overlapping AY dates. See Loan Automation for Overlapping Academic Years (OAYs).

If a new student has a new term-based program with a program start date starting in the middle of a term, and the system is configured to support mid-term program start dates, the system will start the new program using the term containing the Program Start Date.  The Academic Year and Loan Period dates still match the term's start date. The student still only has one active program for the term. The configuration setting is 'Support Mid-Term Program Start Dates: Begins Academic Plan with the term containing the Program Start Date,' see Institution Setup Data Elements.

Nonterm Program Changes

Students may change from a nonterm program to another nonterm program. Many nonterm program changes may be processed as SE or NSE.  An SE change will continue the student in the same Academic Year or same Payment Period. An NSE change will start a new Academic Year. For nonterm PCs, the initial determination of SE or NSE is based on comparing the characteristics of both programs.

Nonterm SE Program Changes

"Substantially Equal" is defined by the Department of Education for nonterm (NT) programs as follows:

  • The student is continuously enrolled at the school;
  • The coursework in the payment period the student is transferring out of is substantially similar to the coursework the student will be taking when the student first transfers into the new program;
  • The payment periods are substantially equal in length, of weeks of instructional time, and credit or clock-hours, as applicable;
  • There are little or no charges associated with the payment period; and 
  • The credits or clock-hours from the payment period the student is transferring out of are accepted toward the new program.

SBL Internal Transfer Overridden

Schools mark courses as transfer="Internal" on the SBL course data; see Program Change Guidance and Attributes Document (SBL Data Dictionary). Regent may systematically override that internal transfer flag for courses involved in an NT SE program change as part of the program change process.  Overriding the internal transfer flag allows the course to be considered as a non-transfer course for payment period length purposes, so that all unit values and weeks values for the payment period are calculated correctly, and the payment period continues as expected. 

The Courses tab displays an indicator denoting when the SIS Internal Transfer flag was overridden for the program change.


Nonterm NSE Program Changes

When the student's prior and new programs do not meet the definition of "Substantially Equal," the program change is processed manually. The program change is performed by a user processing the Program Change in Regent Award, which also satisfies the associated program change task. The user  

Regent will take the following actions when the program change is performed:

  • The user must complete an R2T4 (unless the Payment Period was completed).
  • The new program will start at the beginning of a new academic year.
    • The new AY may overlap with the prior program's academic year dates.
  • Regent Award will leave the previous academic year in place with its original start and end dates.
  • Regent Award will truncate the loan period for the prior program to the end date of the last payment period in which the student received and retained loans.
  • The new academic year will begin when the new program begins (on the new program start date as provided by the school).
  • The new program will start in a new loan period.
    • The student's eligibility will be reduced in the new loan period. If grade level allows, the student's eligibility in the new academic year will be reduced to the remaining eligibility from the academic year under the old program. 
      • If the new program is term-based, Regent may automate loan amounts for the overlap; see Loan Automation for Overlapping Academic Years (OAYs)
      • If the new program is nonterm, the end user will need to manually adjust the student to package in the new AY to ensure proper awarding.
  • If the program change is occurring between AYs, there will be no overlapping loan period, and Regent Award will award normally for the new AY/LP. 

The handling of the academic year and loan periods are fully automated in this scenario; there is no need to create manual academic years using the Program Management Wizard.

Automating Substantially Equal Program Changes

Regent can automatically consider programs as "substantially equal" (SE) if the school has configured the programs as grouped together in the same Program Group within Institution Setup. If a school chooses not to use the Program Group setup, the Substantially Equal determination can be made by a user on a case-by-case basis in the Program Management Wizard in Regent Award. See Institution Setup Data Elements for more details on configuring Program Change automation and Program Groups. See also the Program Change Guidance for sending SBL data for all types of program changes.

SE / NSE Determination Logic for Program Group Automation

If the Institution Setup setting for 'Automate Program Changes for SE Program Groups' is set to "Yes," Regent determines whether two programs involved in a program change are Substantially Equal (SE) for automation purposes. The SE or NSE determination occurs during the Student Batch Load (SBL) process. Note: To use the automation, the institution must configure the Program Groups in Institution Setup before enabling that setting and before loading new Program Change data on the SBL. For additional information on configuring Program Groups, refer to Institution Setup Data Elements.

If Regent automates a Program Change, and the next program ("Program B") has an actual program start date in the future, an end user may also manually re-process the program change as SE or NSE until the new Program B becomes active.

For site-to-site program changes, Regent additionally checks whether the 'COD Attended Entity ID' is the same for both Sites. If the 'COD Attended Entity ID' has different values, the program must be manually processed as NSE.

Regent uses the following logic to determine whether the system can automate the program change as Substantially Equal:

  1. Have the current ("Program A") and next ("Program B") programs been placed in the same Program Group in Institution Setup?
    1. Yes, both programs are in the same Program Group.
      1. Do all the following fields have the same values on Program Setup for each program:
        Academic Calendar Type, Academic Period Type, Academic Unit Type, Units in Academic Year, Weeks in Academic Year?
        1. Yes, the Program Setup settings have the same values.
          1. Is the program term-based or nonterm?
            1. Term-based programs:
              1. Regent considers the two programs as SE
              2. Regent will automate the program change, effectively designating the next ("Program B") program as the program to become active when the student is packaged on or after the Program B start date.
            2. Nonterm programs:
              1. Is there a "Finalized" R2T4 on the final payment period where there is actual enrollment of the current ("Program A") program?
                final payment period where there is actual enrollment: This is the PP related to the last CE for the program (CEP) that has supporting course data.
                1. Yes; then the programs are likely NSE.
                  1. Regent will generate a Program Change task to be completed manually by the end user.
                  2. The end user will have the option to manually reprocess this program change as SE or NSE until the new Program B becomes active.
                2. No; then the two programs are SE.
                  1. Regent will automate the program change, effectively designating the next ("Program B") program as the program to become active.
                  2. The end user will have the option to manually reprocess this program change as SE or NSE until the new Program B becomes active.
        2. No, the Program Setup settings have different values.
          1. The programs must be processed as NSE.
          2. Regent Award will generate a program change task to be completed manually by the end user.
          3. The end user will not have the option to manually process this program change as Substantially Equal.
    2. No, the two programs are not in the same Program Group.
      1. Regent will generate a Program Change task to be completed manually by the end user.
      2. Do the following fields have the same value on Program Setup for both programs: Academic Calendar Type, Academic Period Type, Academic Unit Type, Units in Academic Year, and Weeks in Academic Year?
        1. Yes:
          1. Regent will set the two programs as SE by default.
          2. An end user may manually process the program change as SE or NSE.
        2. No
          1. The two programs are NSE.
          2. The end user will NOT have the option to manually process this program change as Substantially Equal. The program change must be manually processed as Not Substantially Equal.


Change Log

 View a list of changes to this page


DateDescription of ChangeEditor
May 31, 2018Initial page creation based on preexisting Program Change documentationEmily Bivona and Amy Pfarr
July 13, 2023

Moved relevant SE/NSE content here from the Program Change Guidance. Removed duplicated content from that page.

Updated page for current Program Groups functionality.

Cleaned up incorrectly merged duplicate content from Confluence editor.

RI-278 - Getting issue details... STATUS

Jennifer Black