Photo or Art Optional R2T4 – Return of Title IV Funds VASFAA – May 2014 Laurie Owens, Director of Financial Aid

Agenda  Purpose  Process overview  Important deadlines  Modules  Best practices  Common audit findings  Performing hand calculations  Questions?

Purpose Title IV funds are awarded based on the assumption that the student will attend school for the entire period. When a student withdraws or stops attending, the student may no longer be eligible for the full amount of Title IV funds originally awarded. The amount of Title IV grant and/or loan assistance earned by the student must be determined.

VCCS Impact 23 colleges Traditional and various dynamically dated sessions # of R2T4s range from per term for fall and spring; per summer term Modular regulations did not impact volume as expected

Process Overview 1.Identify the involved students 2.Complete the R2T4 Worksheet Enrollment/payment period Withdrawal date or LDA Types of Title IV aid awarded/disbursed Institutional charges Breaks of 5 or more consecutive days 3.Return unearned aid or offer post withdrawal disbursement (PWD)

Identifying Students Report or query in SIS Last enrollment action is withdrawal as opposed to completion 100% of aid earned if attend past 60% date Return calculation still required to determine eligibility for PWD Written confirmation of intent to return Next course must start within 45 days of withdrawn course ending date Custom page for intent to return

Intent to Return

Determining the Withdrawal Date If required to take attendance...  Last date of academic attendance (LDA) as determined by attendance records  Must demonstrate participation in online courses (not just logging in) If not required to take attendance or failure to earn any passing grades...  LDA if known or midpoint for enrollment or payment period If withdrawn during break...  Last day of classes before break

Types of Title IV Aid Unsubsidized Direct Loan Subsidized Direct Loan Federal Perkins Loan Direct PLUS Loan Federal Pell Grant FSEOG TEACH Grant Iraq and Afghanistan Service Grant * Separate calc for VSFAP & GEARUP

Important Deadlines RequirementDeadline Date of determination (unofficial withdrawal) Within 14 days if take attendance Within 30 days of end of period if not Perform R2T4 calculationWithin 30 days of determination Return of unearned funds already disbursed for allowable charges ASAP but no later than 45 days after withdrawal determination Request for acceptance of PWD for loan funds from student or parent Within 30 days of withdrawal determination (school supplies deadline for response: i.e.,14 days) PWD to student’s account for outstanding allowable charges ASAP but no later than 180 days after withdrawal determination PWD to student’s account in excess of charges Loans: ASAP but no later than 180 days after withdrawal determination Grants: ASAP but no later than 45 days after withdrawal determination

Important Deadlines RequirementDeadline Notification to student of grant overpayment Within 30 days of withdrawal determination Return of grant funds by studentWithin 45 days of notification Referral of student to Debt Resolution Services Not specified but ASAP Reporting student to NSLDSNo later than 45 days after notification sent to student Loan repaymentIn accordance with MPN

Modules Completion of at least one class previously exempted students from R2T4 Regulation changed effective 7/1/11 Students now subject to R2T4 if cease attendance at any point prior to completing the enrollment/payment period Program is offered in modules if all courses do not span entire length of the enrollment/payment period Summer impact

The 3 Questions 1. 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 no, student is not a withdrawal. If yes, go to question When ceased to attend or failed to begin attendance in a scheduled course, was the student still attending other courses? If yes, student is not a withdrawal. If no, go to question Did the student confirm attendance in a later module in the enrollment period (starting within 45 days)? If yes, student is not a withdrawal as long as they return. If no, student is a withdrawal and R2T4 may apply.

Modules Seek intent to return to later course starting within 45 days before processing R2T4 Must recalculate aid for dropped or never attended courses prior to R2T4 R2T4 required if last enrollment action is withdrawal not completion Timing is key and results in inequities Problem ED was attempting to resolve can still occur

Example 1 Enrollment PeriodLDA Class 108/22/ /19/13 09/28/13 Class 208/22/ /19/13 09/28/13 Class 308/22/ /19/13 09/28/13 Class 408/22/ /18/13 10/18/13 R2T4 Not Required: Student still attending modular course when withdrawn from traditional courses. Modular course subsequently completed. Last enrollment action is completion on 10/18/13.

Example 2 Enrollment PeriodLDA Class 108/22/ /19/13 10/20/13 Class 208/22/ /19/13 10/20/13 Class 308/22/ /19/13 10/20/13 Class 408/22/ /18/13 10/18/13 R2T4 Required: Student not attending other courses when withdrawn from traditional courses. Last enrollment action is withdrawal on 10/20/13. This student attends more days than the student in Example 1 and owes funds back simply due to timing of withdrawal.

Common Audit Findings #3 on ED’s Top 10 Program Review Findings list #2 and #3 on ED’s Top 10 Audit Findings list Findings on both lists  R2T4 Returns Made Late  R2T4 Calculation Errors

Common Audit Findings Problem: Returns not made within 45-day allowable timeframe -School’s policy and procedures not followed -Inadequate system in place to identify/track official and unofficial withdrawals -No system in place to track number of days remaining to return funds

Common Audit Findings Solution: Returns not made within 45-day allowable timeframe Review and revise policies and procedures to ensure funds are returned no later than 45 days after date of determination Develop R2T4 monitoring/reporting system Provide staff training Periodically review processes, policies, and procedures to ensure compliance Ensure timely communication between offices and/or systems FSA Assessments

Common Audit Findings Problem: R2T4 Calculation Errors Incorrect number of days used in term/payment period Actual clock-hours used instead of scheduled hours Incorrect aid used as “could have been disbursed” Incorrect withdrawal date Mathematical and/or rounding errors

Common Audit Findings Solution: R2T4 Calculation Errors Work with academic offices to confirm when classes meet, including weekends Exclude all class breaks of five consecutive days or more Determine number of clock-hours student is scheduled to attend each day Multiply the number of clock-hours scheduled each day by the number of scheduled days elapsed in the payment period or period of enrollment Implement plan for peer review of each calculation Conduct monthly self-assessment by reviewing random sample of student files

Things to Consider Establishing the correct 60% date Impact of unscheduled breaks resulting from inclement weather closings Breaks between modules Pell Recalculations  All term long  Census locking Permissibility of less than half-time status after loan disbursement

Best Practices Provide thorough R2T4 information on the on College’s website Provide thorough R2T4 information with your award notifications Post notices around campus (particularly in withdrawal locations) warning students about withdrawal implications Educate Counseling and Student Records staff regarding withdrawal implications Summarize withdrawal implications in your SAP policy literature Consider having FAO sign off on withdrawals so students can be informed of impact

Best Practices - Faculty Ensure there is a policy in place for students who never attend to be dropped or coded as such Ensure there is a policy in place for students who stop attending to be withdrawn or coded as such Ensure the last date of attendance is captured if required to take attendance Ensure faculty do not award ‘W’ or ‘F’ grades to students who never attend Ensure there is a policy in place to determine if failing grades are actually unofficial withdrawals Communicate the necessity for accurate and timely reporting by faculty

Hand Calculations Programs measured in credit-hours: # of days in attendance = % of Title IV Earned # of days in the period Programs measured in clock-hours: # of scheduled clock-hours = % of Title IV Earned # of clock-hours in the period

Rounding Percentages  Calculated to four decimal places  Rounded to three decimal places  52/116 =.4482 to.448 to 44.8%  Exception:.6001 through.6004 which are not rounded for determining if past 60% point Dollars and cents  Rounded to nearest penny: $ to $  Repayment amounts can be rounded to the nearest dollar: $ to $637

Hand Calculations See handouts Calendar 2.Calculating the Length of the Period 3.R2T4 Worksheet Traditional 16 week term measured in credit hours Feel free to use cell phone calculators

Hand Calculations Start DateEnd DateWithdrawal Date Pell Disbursed Loans Disbursed (net) College Charges $1411Sub: $990$1075

Results Return of funds by the school? Box O: $ (rounded down to $637) To which Title IV program? Subsidized Return of grant funds by the student? $0 Repayment of the student’s loans? $ via terms of MPN $353 due to rounding

Questions