MASFAA 2013 October 6 th – 9 th, 2013 Indianapolis, Indiana Return of Title IV Funds Jamie A. Malone U.S. Department of Education

Theory Behind the Calculation Student earns Title IV aid through attendance  Percentage of aid earned is equal to the percentage of payment period or enrollment period completed 2

Return Of Title IV Funds Applies only to Title IV eligible students who begin attendance and then completely withdraw, or otherwise cease attending If student enrolled but never attended any classes Student did not establish eligibility for any funds All Title IV aid disbursed must be returned to the programs 3

How Does It Work? If school has disbursed more aid than the student has earned, money is returned to the programs If school has disbursed less aid than the student has earned, a post-withdrawal disbursement will be calculated 4

R2T4 Definitions Standard Terms  Semesters, trimesters – generally 14–17 weeks long  Quarters – generally 10–12 weeks long Non-standard terms – where all coursework is expected to begin and end within a set period of time that is not a semester, trimester, or quarter terms Non-terms – all clock hour programs and credit hour programs that do not begin and end within a set time (self-paced), where courses overlap, where sequential courses do not begin, and end within a term 5

R2T4 Definitions Week of instructional time Any seven consecutive day period with at least one day in which scheduled instruction or examination occurs Does not include homework time, vacation time, orientation, or counseling 6

Offered In Modules Regulations define a program “offered in modules” A course or courses in program do not span entire length of payment period or period of enrollment Doesn’t matter what “modules” are called at the institution 7

Credit Hour Programs Offered In Modules Standard term program “offered in modules” Two 8-week sessions within a 16 week semester Three 5-week sessions within a 15 week semester Two 6-week sessions within a 12 week quarter Three 4-week sessions within a 12 week quarter Winter “inter-session” or “J term” between fall and spring semesters 8

Credit Hour Programs Offered In Modules Student considered to be withdrawal if does not complete all days scheduled to complete within payment period/term School must document completed all courses with a passing grade If no passing grade in last scheduled course, school must demonstrate student completed period 9

R2T4 Calendar Days Credit Hour Modular Program Total calendar days include all days on which the student was scheduled to attend Days of completed courses count if course does not span length of term Exclude scheduled breaks of at least 5 consecutive days when student not scheduled to attend a module or other course offered during that period For a withdrawn student who has made schedule changes Do not count days of withdrawn courses after official withdrawal prior to complete cessation of attendance 10

R2T4 Calendar Days Credit Hours Modular Program The denominator in R2T4 calculation Step 2 is “total days” and includes all days used to determine the aid awarded except-- any institutionally scheduled breaks of five or more consecutive days And periods of time that the student was on an approved LOA 11

Credit Hour Programs Offered In Modules Student in modular program not considered a withdrawal if he/she provides written confirmation of intent to attend a future module in period of enrollment  Must be provided at the time of withdrawal Student may change return date in writing, but must provide change prior to original return date Future module must begin within 45 calendar days in a non-standard and non-term program 12

After Written Confirmation Of Return Student is considered to be withdrawal if does not return as scheduled Withdrawal dates back to time that confirmation originally provided  Determine withdrawal date and days of attendance as if confirmation of future attendance never provided 13

Offered in Modules - Example A  Fall and Spring = standard terms where all courses last for full 15 weeks; not considered to be “offered in modules”  Summer = three 5-week sessions (combined to be a standard term offered in modules) Students can enroll in any one, two or all three summer sessions Students enrolled in the 5-week summer sessions are considered enrolled in programs “offered in modules” because none of the sessions span the entire length of the term (the 15-week period) 14

Offered in Modules – Example A Session 1 5 weeks Session 2 5 weeks Session 3 5 weeks 33 days Student enrolls in all three summer sessions. Completes session 1, begins session 2, and stops attending on day 10. No withdrawal or confirmation to return. R2T4 is required. Recalculate Pell before R2T4. Withdrawal date is day 10 of session days ÷ 103 days =.4369 = 43.7% 2 days 15

Example B 16 Part 1 33 days Part 2 33 days 15-week Full Term 103 days. 9/09 to10/1110/18 to 11/1511/18 to12/20 9/09 – 12/20 Part 3 33 days Standard Semester Academic year is 30 weeks, 103 days Also offers courses in 3 Parts of term, Part of term is 5 weeks,33 days 2 days

Jamie Student 17 Part 1 N/E Part 2 3 credits Part 3 3 credits 2 days 9/09 begins attendance in 6 credits in Full Term 10/01 withdraws from 3 credits in Full Term 11/15 withdraws from 3 credits in Full Term 10/18 begins 3 credits in Part 2 11/15 completes 3 credits in Part 2 11/15 withdraws 3 credits in Part 4 Full Term enrolled for 6 credits

Jamie Student Enrollment ends 11/15 with completed course and official withdrawal* Was to attend until 12/20 R2T4 required Withdrawal date is 11/15, 68 days Enrollment period is 09/09 to 12/20 = 103 days 68 ÷ 103 =.6602 = 66.0% *complete and withdraw same day = withdrawal 18

Rob Student 19 Part 1 3 credits Part 2 N/E Full Term 6 credits Part 3 3 credits 2 days 9/09 begins attendance in 6 credits in Full Term 9/25 withdraws 3 credits in Full Term 12/20 completes 3 credits in Full Term 09/09 begins attendance in 3 credits in Part 1 10/11 completes 3 credits in Part 1 12/10 withdraws from 3 credits in Part 3 11/18 begins 3 credits in Part 3

Rob Student Enrollment ends 12/20 with completed course No R2T4 required 20

Barbie Student 21 Part 1 3 credits Part 2 N/E Full Term 6 credits Part 3 N/E 2 days 9/09 begins attendance in 6 credits in Full Term 9/17 withdraws 6 credits in Full Term 9/09 begins attendance in 3 credits in Part 1 9/27 withdraws 3 credits in Part 1

Barbie Student Enrollment ends 09/27 with official withdrawal Was to attend until 10/11 R2T4 required Withdrawal date is 09/27, 19 days Enrollment period is 09/09 to10/11, 33 days 19 ÷ 33 =.5757 = 57.6% 22

Ken Student 23 Part 1 6 credits Part 2 6 credits Full Term N/E Part 3 N/E 2 days No confirmation of return and no attendance 9/09 begins attendance in 6 credits in Part 1 09/17 withdraws 6 credits in Part 1

Ken Student Enrollment ends 9/17 with official withdrawal Was to attend until 11/15 R2T4 required Withdrawal date is 9/17, 9 days Enrollment period is 9/09 to 11/15, 68 days 9/68 =.1324 = 13.2% 24

Credit Hour Programs Offered In Modules Nonstandard & Nonterm Programs Student considered to be withdrawal if not scheduled to begin another course in period of enrollment for more than 45 calendar days 45 days measured from end of module ceased attending 25

Non-Term In Modules 26 Mod 1 33 days Mod 2 33 days. 09/09 to 10/11 11/18 to 12/20 Mod 3 33 days Mod 4 33 days Mod 6 33 days Mod 5 33 days 01/06 to 02/07 02/10 to 03/14 03/17 to 04/18 10/14 to 11/15 Academic year is 30 weeks, 208 days Enrollment is for full academic year

Non-Term in Modules 9/09 begins attendance 11/07 withdraws Mod 2 and Mod 3 11/07 confirms return Mod 4 on 01/06 Because will be out of school more than 45 days, R2T4 required Withdrawal date is 11/07, 60 days Enrollment period is full academic year, 208 days 60 ÷ 208 =.2885 = 28.9% 27

Non-Term in Modules 9/09 begins attendance 11/01 withdraws Mod 2 11/01 confirms will return Mod 3 on 11/18  No R2T4 required Returns 11/18 and completes Mod 3 01/15 withdraws Mod 4 No confirmation of return received so R2T4 required Withdrawal date is 01/15  54 days 9/09 to 11/01  59 days 11/18 to 01/15 Enrollment period is full academic year, 208 days 113/208 =.5432 = 54.3% 28

Clock Hour Programs Student considered to be withdrawal if does not complete all clock hours and weeks of instructional time that was scheduled to complete School must document completed all courses with a passing grade If no passing grade in last scheduled course, school must demonstrate student completed period 29

Is Student A Withdrawal? 1. Did the student cease to attend before completing or fail to begin attendance in a course scheduled to attend?  If yes, go to question 2.  If no, student not a withdrawal 2. When ceased to attend or failed to begin attendance in a scheduled course, was the student attending other courses?  If yes, student not a withdrawal  If no, go to question 3 3. Did the student confirm attendance in a later module in the payment/enrollment period (45 day rule, if applicable)?  If no, student is a withdrawal.  If not a withdrawal, Pell recalculations may apply 30

Return After Withdrawal Modular term-based credit hour program Withdrawn student may return to same program prior to end of payment period/period of enrollment Student eligible for any Title IV funds for which eligible prior to withdrawal Clock hour/non-term credit hour program Withdrawn student may return to same program within 180 calendar days Student eligible for any Title IV funds for which eligible prior to withdrawal 31

R2T4 & Taking Attendance R2T4 calculates Title IV aid earned based upon student attendance − Aid prorated based upon days or hours student attended Should use best information available to determine withdrawal date since it directly impacts dollars 32

Required To Take Attendance School is required to take attendance if Outside entity requires that attendance be taken OR School has own requirement that instructors take attendance OR Outside entity or school has requirement that can only be met by taking attendance or a comparable process 33

Required To Take Attendance If required to take attendance— For some students—use attendance records for those students For a limited period of time—use attendance records for withdrawals during that limited period of time On a specific date—NOT considered to be required to take attendance 34

Attendance Per Regulation Attendance must be “academic attendance” or “attendance at an academically-related activity”. Examples include  Physical class attendance where there is direct interaction between instructor and student  Submission of an academic assignment  Examination, interactive tutorial, or computer- assisted instruction  Study group assigned by school  Participation in on-line discussion about academic matters  Initiation of contact with instructor to ask question about academic subject 35

Your Feedback Please Please provide any comments to my supervisor- Jo Ann Borel Title IV Training Supervisor AND/OR complete the survey at: Thanks much! 36

Questions ???? Jamie A. Malone Training Officer U.S. Department of Education