rawr……or r2t4 crystal bruntz director of financial aid avila university

RAWR……or R2T4Crystal Bruntz

Director of Financial AidAvila University

Return of Title IV Funds

IT’S COMPLEX!!! Has its own volume in the Federal Student

Aid Handbook (Volume 5) 124 pages of material Plus 77 pages of case studies

Return of Title IV Funds An institution is required to determine earned and

unearned portion of Title IV aid when a student ceases enrollment prior to the planned completion date

Post-withdrawal disbursement – Amount paid to student as earned Title IV funds after R2T4 calculation is completed

Unearned funds – Funds that must be returned to appropriate Title IV program

Return of Title IV Funds Title IV recipient:

Student who actually received a disbursement of Title IV grant or loans funds, or who met the qualifications for a late disbursement of Title IV funds [R2T4 does not apply to Federal Work-Study (FWS)]

If student never began attendance, R2T4 does not apply (all Title IV aid must be cancelled)

Overview of R2T4 Process

Determine student’s withdrawal date

Calculate percentage of payment period or period of

enrollment completed

Determine amount earned by applying percent

completed to total Title IV aid disbursed and that could

have been disbursed

Decide if earned funds are due to the student through a

Post-Withdrawal Disbursement; obtain

permissions and credit as allowed

Decide if unearned funds are due to Title IV programs, and whether they are due from the student or the school

General Principles Required to take attendance – Can be required by an

outside entity (such as an accreditor or state agency), or the institution itself, or a requirement that can be met only by taking attendance

Must use official attendance records Could apply to a subset of students, or for a

certain period of time

Not required to take attendance

General Principles Withdrawal date – The withdrawal date is used to calculate

the amount of earned and unearned funds

Determination of the withdrawal date is driven by whether the institution is required to take attendance

School should use best information available to determine withdrawal date and document it.

General Principles Date of determination

Official withdrawal – Student begins school’s withdrawal process or provides notification he or she will withdraw, or both

o Date of determination is the earlier of the two dates

Unofficial withdrawal – Date of determination is the date the school becomes aware the student has ceased attendance

At schools required to take attendance – Date of determination should be no more than 14 days after the last date of attendance

General Principles Institutional charges:

Includes tuition and fees (required of all students in program)

Room and board, if contracted with the school

Books, supplies, materials, and equipment, if the student cannot reasonably get them anywhere besides from the school

General Principles Payment period versus period of enrollment:

The program type determines which measure is used for the calculation:

For students who withdraw from a trimester, semester, or quarter program – use payment period

For students who withdraw from a nonstandard term-based or non term-based program – School can choose to use either payment period or period of enrollment

Scheduled Breaks

At least five (5) scheduled days How to determine the length of a scheduled

break: Determine the last day that class is held before a

scheduled break – the next day is the first day of the scheduled break.

The last day of the scheduled break is the day before the next class is held.

Modular Programs Modules are courses in a student’s program that do not

span the entire length of the payment period or period of enrollment

Example: School has 14-week summer term, during which students can enroll in any or all of the following sessions:o Two 5-week sessions offered one after the

othero A single 14-week session

Modular Programs Examples:

Two 5-week sessions offered one after the other A single 14-week session

A student enrolled in one or both 5-week sessions is considered to be enrolled in a program offered in modules

A student enrolled in one 5-week session and the 14-week session is considered to be enrolled in a program offered in modules

A student enrolled in only the 14-week session would not be considered enrolled in a program offered in modules

Modular Programs If student begins one or more modules, but does not begin

next module he is scheduled to attend and does not provide written confirmation at time of withdrawal stating his planned attendance in a module beginning later in same payment period or period of enrollment, he is considered to have withdrawn because he did not complete all the days he was scheduled to attend

Under current regulations, completion of one course in one module in a term-based credit-hour program no longer means student has not withdrawn

Determining Withdrawal from a Modular Program

Determine withdrawal by asking three questions:

1. After beginning attendance in the payment period or period of enrollment, did the student cease attendance or fail to begin attendance in a course he or she was scheduled to attend?

- If no, this is not a withdrawal

- If yes, proceed to question 2


2. When the student ceased attendance or failed to begin attendance in a course he or she was scheduled to attend, was the student still attending other courses?

- If yes, this is not a withdrawal. Recalculate aid per applicable program regulations and school policies

- If no, proceed to question 3


3. Did the student confirm in writing his or her intent to attend a course in the module beginning later in the term?


- If no, R2T4 regulations apply

Modular Programs

3. Did the student confirm in writing his or her intent to attend a course in the module beginning later in the term?


- If no, R2T4 regulations apply

Written Confirmation of Future Attendance

ED realized that modular programs often lend themselves to flexible and changing enrollments, so it provided a way for schools to be excused from doing R2T4s for class schedule changes

This is referred to as the intent to return notification


Student must confirm intent to attend module later in same period

Must be a positive confirmation from the student Can be electronic Cannot assume student will come back for classes already

scheduled New enrollment in classes later in the module show intent to

return


Timing: Must be received close to date student ceased

attendance

Must be received before time period elapses that school must take R2T4-related action required by regulation

Student Returns to School During Period

If student returns in same payment period or period of enrollment before R2T4 process is completed, no requirement to complete R2T4 process

If student returns to school within same payment period or period of enrollment, or within 180 calendar days for clock-hour or nonterm credit hour programs after R2T4 has been completed, school must “undo” R2T4 calculation

Student Says They Will Return, But…

If the R2T4 calculation is not completed because a student says she will return later in the period, but the student does not return:

The withdrawal date is the last date of attendance, the midpoint, or the last date of attendance in an academically-related activity (depending on whether school is required to take attendance)

Return of Title IV Funds

Earned vs. Unearned aid 60% point

Student completes more than 60% of the PP or POE, student earned 100% of aid.

Does not dictate institutional refund policy• Refund policy does not affect the amount of Title IV Aid

the student has earned.

Determining Percentage of Days Completed

For credit-hour programs:

Days attended

Days in period

= % completed

Determining Percentage of Days Completed

However, if the student dropped the classes in the 2nd and 3rd modules before ceasing attendance in the 1st module, the number of days in the period would be only the days in the first module

Scheduled breaks of more than 5 consecutive days should be excluded when calculating percentage completed

Audit Findings (NASFAA) Calculation Errors

Late R2T4 calculation and/or return of unearned Title IV funds

Incorrect number of days

Ineligible funds used as aid that “could have been disbursed”

Improper treatment of grant overpayments

Incorrect withdrawal date

Audit Findings (NASFAA) Mathematical and/or rounding errors

School’s policies and procedures not followed

Returns not made within allowable time frame (45 days)

Inadequate system in place to identify and track official and unofficial withdrawals

No system in place to track number of days remaining to return funds

Questions?

THANK YOU!!!Crystal Bruntz

Director of Financial AidAvila University

[email protected]

mailto:[email protected]

rawr……or r2t4 crystal bruntz director of financial aid avila university

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