I am not sure that I am following the scenario.
If a student is not qualified for federal aid then SAP isn't mandated. However, many states and institutions have a SAP policy that applies to all students therefore, the student should be counseled.
If the student is strong (2.8 GPA) and must drop out due to a lack of funding it is important to counsel with them in a one to one setting. They may be able to secure an individual loan through a lending institution. Unfortunately, a student's economic situation may not change.