Current Title IV financial aid eligibility is limited to students enrolled in eligible programs as defined in 34 C.F.R. §668.8. Historically, eligibility requirements revolved around several factors including whether the programs were tied to a credential, the length of the program, and whether a student made satisfactory academic progress (SAP). In 2005, the Higher Education Reconciliation Act (HERA) created direct assessment programs as an alternative path to Title IV financial aid eligibility for students enrolled in programs approved by the Department of Education. Although enacted as a means of opening financial aid eligibility to students enrolled in competency-based education (CBE), the current regulations have not mitigated eligibility challenges around satisfactory academic progress, credit hour, and academic year regulations. As a result, only a few institutions have chosen to use the direct assessment option and CBE programs continue to struggle with financial aid regulatory compliance.