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Return of Title IV Funds Policy

I. Policy Statement

Federal Regulation 34 CFR Section 668.22 Treatment of Title IV funds when a student withdraws

(a) General (1) When a recipient of title grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date.

As long as a student begins attendance in a payment period or period of enrollment, the student begins earning Title IV funds and return of Title IV funds (R2T4) rules in 34 CFR 668.22 apply. The school must perform the R2T4 calculation if the student completely withdraws at any point prior to the 60 percent point of the payment period/period of enrollment. An R2T4 calculation is required even if the student only attends classes for one day or receives a full refund of institutional charges under institutional refund policies. A student who begins attendance starts earning Title IV funds to pay, not only for institutional charges, but for noninstitutional charges, like off-campus room and board, books and supplies, transportation, and miscellaneous personal expenses. Therefore, you must perform an R2T4 calculation and make any post-withdrawal disbursement of Title IV funds, as well as deliver any Title IV credit balance for which the student is eligible as a result of that calculation. Your institution’s recordkeeping system and/or financial aid management system (FAMS) must have an audit trail in place to show the actions it has taken in this situation, e.g. system entries showing the registration, enrollment status, institutional charges, removal of registration and charges, etc.

II. Definitions

The amount of federal aid that a student must repay is determined by a formula as specified in 34 CFR 668.22 of the Higher Education Act of 1965, as amended.

A calculation will be performed by the Financial Aid Office based upon the following definitions:

  • Unofficial withdrawal – If a student does not complete the published official withdrawal process but ceases attendance in a scheduled payment period, the student is considered an unofficial withdrawal.
  • Official withdrawal – The university has a defined process for students to drop and/or withdraw from all classes during a payment period.
  • Withdrawal Date/Last date of attendance – For official withdrawals, the date the student began the withdrawal process or officially notified the institution of his/her intent to withdraw, whichever is later, will be considered the last date of attendance or withdrawal date. For an unofficial withdrawal, this is the date of the last day a student participated in an academically related activity. For example, a professor reports the last of date of attendance for a student who earns an F for non-attendance but failed to officially withdraw. It is possible for a student to earn a passing grade in a module early in the payment period and then become an unofficial withdrawal if they cease attendance in scheduled courses after establishing at least one day of attendance. The university must determine that the student established attendance and stopped attending. By documenting the last date of attendance with F grades, the university can distinguish between students who earned the failing grade and those who failed to attend the scheduled period.
  • Date of Determination – This is the effective date or when the university learned of the student’s withdrawal. For official withdrawals, this is the date the student began the withdrawal process. For unofficial withdrawals, this is the date the university learned the student was no longer attending. For example, when grades are submitted at the end of the term, failing grades may inform with the last date of attendance that a student ceased attendance earlier than scheduled and an R2T4 calculation is required.
  • Institutional charges - The original institutional charges for tuition, fees, room and board that were assessed at the time of enrollment.
  • Payment period – The payment period is the semester for which the student is scheduled to attend. The regular semester and any modules associated with a regular semester are included in the payment period.
  • Module – A module is any class that doesn’t span the entire length of the payment period. Any class that doesn’t begin within one week of the published start date and end within one week of the published end date is a module for R2T4 purposes. Effective 7/1/2021, students who completed a module that comprises at least 49% of the payment period and earned passing grades in Title IV eligibility courses that total at least half-time enrollment do not require an R2T4 calculation. If a student ceases attendance but is scheduled to attend a future module within the payment period, the student must provide active confirmation in writing to the Financial Aid Office that he/she plans to return within 45 days and continue attendance in the same payment period or an R2T4 calculation must be completed.
  • Days in the numerator – Used in the R2T4 calculation as the percentage of days attended in the payment period. For a full semester course, count the days from the published start date to the last date of attendance, excluding any break of five or more calendar days. For a module, count the days from the earliest Title IV course start date to the last date of attendance, excluding any break of five or more calendar days.
  • Days in the denominator – Used in the R2T4 calculation as the percentage of days scheduled to attend in the payment period. For a full semester course, count the days from the published start date to the published end date, excluding any break of five or more calendar days. For a module, count the days from the earliest Title IV course start date to the published end date of the latest Title IV course, excluding any break of five or more calendar days.

III. Policy Procedure Recommendations

The return of Title IV funds (R2T4) requirement is a complex and time-sensitive process involving a great deal of interoffice cooperation and coordination. The Registrar, Financial Aid, and Business Office must develop and coordinate procedures to ensure that all students are processed in a timely and efficient manner.

  • Registrar – enters the appropriate withdrawal and status codes for each student on SFAWDRL within 5 business days of learning of the student’s withdrawal. After grades are posted, enter the appropriate withdrawal and status codes for each student who earned all F’s or a combination of F’s, W’s, and I’s.
  • Student Accounts/Business Office – ensures that withdrawn students’ accounts are adjusted correctly based on their official withdrawal date
  • Financial Aid Office – on a weekly basis, runs a report to identify withdrawn students, performs R2T4 calculations in Banner, and double-check calculations with DOE module on COD, and returns the appropriate funds to COD within 45 days of the withdrawal date. The RO runs a report that captures all low grades and the last day of attendance, at the end of every term to determine if they have earned aid.
  • Faculty - will regularly monitor participation using TNS systems to identify students who may have stopped attending. Faculty must complete two Starfish surveys during the course of the semester to record accurate dates in which students stop attending classes for Return of Title IV purposes. The first is the No Show/Never Participated Survey at the conclusion of the add/drop period. The second is the Stopped Participating/Stopped Attending Survey in the second half of the semester. While these surveys are sent by the Provost’s Office, school-level leadership is responsible for messaging faculty about the need to complete these surveys each semester. Faculty must also provide a last day of attendance for all students who receive a grade of F or I.

IV. Enforcement

All students receiving Title IV grants or loans will be subject to R2T4 calculations and a return of funds will automatically take place. Students may then have an outstanding balance on their student accounts for which they are responsible for.

V. Policy Management

Financial Aid Office

VI. Exclusions

The U.S. Department of Education notifies institutions when and if there are exceptions that can be made. Normally this occurs during times of national disasters.

VII. Effective Date

Effective date will be July 1, 2022.

VIII. Review and Approval Process

  • 10/17/2022 - Submitted to Academic Policy Group, presented by Grace Fend, Deputy University Registrar 1/25/2022 - Approved by Academic Policy Group

IX. Appendices & References

https://fsapartners.ed.gov/knowledge-center/fsa-handbook/2021-2022/vol5/ch1-withdrawals-and-return-t

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