Return of Title IV (R2T4)The basics of R2T4 plus a look at the rules for programs offered in modules

Return of Title IV Funds• The requirement for an institution to determine earned and unearned portions of Title IV aid when a student ceases to maintain scheduled enrollment for the payment period or period of enrollment

Current rules are located in Volume 5 2015-2016 Federal Student Aid Handbook

• In the case of a program that is measured in credit hours, the student does not complete all the days in the payment period or period of enrollment that the student was scheduled to complete

• In the case of a program that is measured in clock hours, the student does not complete all of the clock hours and weeks of instructional time in the payment period or period of enrollment that the student was scheduled to complete; or

• In the case of a non-term or non-standard term program, the student is not scheduled to begin a class within a payment period or period of enrollment for more than 45 calendar days after the end of the module the student ceased attending unless the student is on an approved leave of absence

A student is considered withdrawn if:

Payment Period vs Period of Enrollment

• When a student withdraws from a semester, trimester or quarter program – payment period must be used

• When a student withdraws from a non-term or non-standard term program – the institution has the choice of using either payment period or period of enrollment• Must use the same basis for all students within the

same program

Basic Terminology

Title IV Recipient• Student who begins attendance and has received a Title IV grant or loan disbursement or meets the conditions for a late disbursement• FWS does not apply to R2T4

• If student never actually begins attendance – R2T4 does not apply and all Title IV aid must be cancelled

Basic TerminologyDate of Determination• Used to determine the various deadlines associated with

R2T4 calculations (see chart on page 5-118 of the 2015-16 FSA Handbook)

• Official withdrawal: the date the student begins the withdrawal process or provides official notice of intent to withdraw – whichever is later

• Unofficial withdrawal: the date the institution becomes aware that the student ceased attendance

• Schools required to take attendance should have a date of determination that is no later than 14 days after the student ceased attendance

Basic TerminologyWithdrawal Date• Used to calculate the amount of earned and unearned Title IV

funds

For institutions not required to take attendance:• Official withdrawal: the date the student begins the withdrawal

process or provides official notice of intent to withdraw – whichever is earlier

• Unofficial withdrawal: the date the student last attended an academically related activity or the midpoint of the payment period or period of enrollment• must determine this date no later than 30 days after the end of the

earliest of (1) payment period/period of enrollment (2) academic year (3) educational program

Basic Terminology

Withdrawal DateFor institutions required to take attendance:• The withdrawal date is always the last date of academic attendance as determined from attendance records• This date is used for all forms of withdrawal – official or unofficial

• The requirement to take attendance can be mandated by an outside agency, the institution itself, or a requirement that can only be met by taking attendance

Basic TerminologyAcademically related activities• Physically attending a class• Submitting an assignment• Taking an exam, completing an interactive tutorial or participating in computer-assisted instruction

• Attending a school assigned study group• Participating in an online discussion about academic matters

• Initiating contact with faculty to ask a question about the academic subject of the course

Basic Terminology

Aid disbursed• Title IV funds that were disbursed prior to the date the institution determined the student withdrew

Aid that could have been disbursed• Generally, as long as the condition for late disbursement has been met, any undisbursed Title IV funds for the period for which the calculation is performed

Basic TerminologyInstitutional Charges• Used to determine the amount of unearned aid that

the institution must return• Includes tuition• Fees, if required by all students in the program• Room and board, if contracted with the institution• Expenses for required course materials, if the

student does not have a real and reasonable opportunity to purchase the materials from any place but the school

Basic TerminologyPost-withdrawal disbursement (PWD)• A disbursement of earned funds that was not received prior to the withdrawal• A PWD of grant funds does not require a student’s permission.

Student or parent permission must be obtained prior to making a loan PWD

Unearned funds• Funds that must be returned to the Title IV program• The institution, student or both must return the funds in a specified

order

The R2T4 Process

Return all unearned funds within 45 days of date of determination

Determine if unearned funds are due to Title IV programs (due from school or student)

Determine if earned funds are due to the student as a PWD (obtain required permissions)

Calculate the amount of aid earned

Calculate the percentage of payment period or period of enrollment completed

Identify the aid disbursed and aid that could have been disbursed

Determine the date of determination and the withdrawal date

Defining a Program Offered in Modules

Course(s) in the program do not span the entire length of the payment period or period of enrollment

• Determination that a program is offered in modules can change from one payment period to another and is student specific

• Student is considered to be in a program offered in modules if he or she is enrolled in one or more of these courses

Defining a Program Offered in Modules

• Example:• Two 8 week sessions offered one after the other• One 16 week session

• A student enrolled in either (or both) of the 8 weeks sessions is considered to be in a program offered in modules

• A student enrolled in the 16 week session and either of the 8 week sessions is considered to be in a program offered in modules

• A student enrolled only in the 16 week session is not considered to be enrolled in a program offered in modules

Determining Withdrawal• Prior to July 2011, a student who completed one course in

one module in a term based credit hour program was not considered withdrawn, that is no longer the case

• The Department of Education developed a set of three questions to assist with identifying if a student has withdrawn from a program offered in modules

• The questions are always accurate, but often it helps to draw a visual of the enrollment scenario to use while going through the questions

Determining Withdrawal

After beginning attendance in the payment period or period of enrollment, did the student cease to attend or fail to begin attendance in a course he or

she was scheduled to attend?

If the answer is no, this is not a withdrawal.

If the answer is yes, go to question 2.

When the student ceased to attend or failed to begin

attendance in a course he or she was scheduled to attend, was the student still attending

any other courses?

If the answer is yes, this is not a withdrawal but a recalculation of aid may

be required per regulations and

institutional policies.

If the answer is no, go to question 3.

Did the student confirm attendance in a course in a

module beginning later in the period?

If the answer is yes, this is not a withdrawal,

unless the student does not return.

If the answer is no, this is a withdrawal.

Written Confirmation• Programs offered in modules allow greater flexibility for enrollment

changes, and those changes often lead to situations that require an R2T4 calculation

• Written confirmation of intent to return at a later date within the same period is the only way an institution can avoid having to complete an immediate R2T4 calculation

• Points to remember:• Must be positive confirmation from the student• Must be written (electronic is acceptable)• Must be obtained “at the time of the withdrawal” – this means close to the date the

student ceased attendance and prior to the time when the calculation must be completed

• New enrollment for later in the period can be used as confirmation of intent to return• Enrollment that was previously scheduled (even if for later in the period) cannot be

used as confirmation of intent to return

The Student Does Not Return…• When a student confirms intent to return in a future

module within the same period, the institution must confirm that the student has in fact returned on that date. If the student does not return:• The Date of Determination is the date the student certified he or

she would return

• The Withdrawal Date is the last date of attendance, the last date of attendance in an academically related activity, or the midpoint of the payment period or period of enrollment (varies based on requirement to take attendance)

Then the Student Returns…• If a student returns within the period and prior to the

completion of the R2T4, there is no requirement to complete the process, but the institution may not delay the R2T4 process to see if the student will return

• If the R2T4 process is completed, and then the student returns within the same period (or within 180 days for clock hour or non-term credit hour programs); the R2T4 calculation must be “undone”• The original award amounts for Title IV programs must be restored,

with no adjustments required for partial attendance of a module

• Exception: if an entire module was originally scheduled, but the student never began attendance in the module, then aid must be adjusted accordingly.

Determining Percentage Completed

Credit hour programs:

• Scheduled breaks of 5 or more consecutive days and days the student was on an approved leave of absence should be excluded

Total days completedTotal days scheduled in period

= % Completed

Determining Percentage Completed

Clock hour programs:

Scheduled hours at withdrawalTotal hours in period

= % Completed

Determining Percentage CompletedNon-term credit hour programs:• If student is self paced:

• End date and number of days in payment period or period of enrollment will be unique for each student

• Must project an end date of the period based on the student’s progress prior to the withdrawal date; and

• Use projected end date to calculate the days in the payment period or period of enrollment

Common Modular Scenarios• Withdrawal and no certification of intent to return:

Date of Determination: 5/22, Withdrawal Date: 5/22Completed: 5/14-5/22 / Scheduled: 5/14-7/8

Common Modular Scenarios• Drop future class during a break:

Date of Determination: 3/15, Withdrawal Date:3/11Completed: 1/17-3/11 / Scheduled: 1/17-5/13 (exclude 7 day break)

Common Modular Scenarios• Withdrawal from current class and drop future class:

Date of Determination: 5/21, Withdrawal Date:5/21Completed: 5/13-5/21 / Scheduled: 5/13-8/18

Common Modular Scenarios• Withdrawal from class and certification of return, does not

return:

Date of Determination: 5/11, Withdrawal Date: 3/5Completed: 1/17-3/5 / Scheduled: 1/17-5/11 (exclude 7 day break)

Common Modular Scenarios• Several enrollment changes with breaks in between:

Date of Determination: 5/11, Withdrawal Date: 4/30Completed: 1/17-4/30 (exclude 6 day break) / Scheduled: 1/17-5/11

QUESTIONS?Contact Information:Laura BeerUniversity of Maryland University CollegeEmail: Laura.Beer@umuc.eduPhone: 240-684-5643