Return of Title IV Funds A NASFAA Authorized Event Presented by [Name of Presenter/Association] [Location] [Date], 2017.

Return of Title IV Funds A NASFAA Authorized Event Presented by [Name of Presenter/Association] [Location] [Date], 2017

Lesson 1: Introduction to Return of Title IV Funds

Key Concepts Withdrawal Title IV Recipient Title IV Aid
Student ceased attendance in all classes during payment period/period of enrollment Title IV Recipient Received federal grant or loan funds Meets the requirements to receive a late disbursement of federal loan funds Title IV Aid Certain federal financial aid programs subject to R2T4

Return of Title IV Funds Formula
Earned Aid Disbursed or undisbursed federal funds the student may keep Post-Withdrawal Disbursement Undisbursed federal funds the student earned and could receive Unearned Aid Disbursed federal funds for which the student doesn’t qualify

Institutional Refund Policies
Amount of unearned Title IV aid to return is independent of school’s refund policy Title IV regulations do not govern school’s refund policy

When R2T4 Requirements Apply
Credit-hour Clock-hour Nonterm and Nonstandard term Module

When R2T4 Requirements Don’t Apply
Situation Perform R2T4 Calculation School Returns Funds Student Returns Funds Partial withdrawal No Did not establish Title IV eligibility Deceased student Yes

Quick Quiz: 1. Define “Title IV recipient.”
2. Which Title IV programs are not subject to the return of Title IV funds requirements? 3. Define “unearned aid.” 4. When is a student considered to have withdrawn from a credit-hour program? 5. Name two situations for which the return of Title IV funds requirements do not apply. Page 5

What do you think the rationale is for the R2T4 requirements?
What challenges might you have explaining R2T4 requirements to students? Page 6

Learning Activity: Determining if the Return of Title IV Funds Requirements Apply Page 7

 Learning Activity: Do the R2T4 Requirements Apply?
1. Marco is enrolled for four classes at Roman University. His financial aid for the term consists of a Federal Pell Grant, FSEOG, and a Direct Subsidized Loan. During the third week of the term, he drops all of his classes because he wants to transfer to a school closer to home.  Yes  No  The R2T4 requirements do apply to Marco because he is a Title IV recipient and withdrew from all of his classes in the term. Page 7

 Learning Activity: Do the R2T4 Requirements Apply?
2. Natalie is registered for five classes at Zion State University. Her financial aid for the term consists of a Direct Subsidized Loan and Federal Work-Study (FWS). She drops her calculus class after the first exam because the class is much harder than she expected.  Yes  No  The R2T4 requirements do not apply to Natalie because she only withdrew from one, but not all, of her classes for the term. Page 7

 Learning Activity: Do the R2T4 Requirements Apply?  Yes  No
3. Fina is studying sculpting at the Fine Arts Institute. She is registered for three classes for the fall semester. Her financial aid for the term consists of a state grant and a scholarship from the Sculptors Benevolence Fund. She drops all of her classes the second week because she broke her right arm and won’t be able to participate in her classes while her arm is in a cast.  Yes  No  The R2T4 requirements do not apply to Fina because she is not a Title IV recipient. Page 7

Lesson 2: Determining the Withdrawal Date

Required to Take Attendance
A school is required to take attendance if: Requirement imposed by outside entity Voluntarily takes attendance Required by the program Includes taking attendance for: A limited period of time Certain populations

Academic Attendance Includes Does not include
Physically attending class Submitting an academic assignment Attending a study group assigned by the school Participating in an academic online discussion Academic questions to course faculty Does not include Living in institutional housing Using school meal plan Participating in student-organized group Logging into an online course without active participation Participating in academic counseling or advising

Not Required to Take Attendance
Withdrawal date depends on whether the student is an: Official withdrawal Unofficial withdrawal

Unofficial Withdrawals
Occurs when a student drops out without notifying the school Schools have a choice: Midpoint of the payment period Last date of attendance in an academically related activity that is earlier Timeframe for determination

Should all schools be required to take attendance in order to establish a withdrawal date for return of Title IV funds purposes? Why? Why not? Which office/individual on your campus would be the most appropriate to return Title IV funds and to perform R2T4 calculations? Why?* Should multiple offices be responsible for R2T4-related functions? Which offices would perform which functions and why?* * Compare your responses once you complete the Learning Activity on page 18. Page 17

Withdrawal from Programs Offered in Modules
Course does not span the entire payment period A withdrawal occurs when student: Ceases attendance before completion of payment period as scheduled, AND No written confirmation of future attendance provided

Example: Mitch and Brandy
Semester (14 weeks) Module 1 (7 weeks) Module 2 Mitch Enrolled in: 14-week semester Modules 1 and 2 Considered enrolled in a program with modules Brandy Enrolled in: 14-week semester (three courses) Not considered enrolled in a program with modules

Written Confirmation of Future Attendance
Paper or electronic format Student may change date under certain circumstances Nonterm and non-standard term requirements

Example: Elsa Enrolled in 15-week semester
Ceases attending classes on Day 20 of first module Does not provide written confirmation Module 1 (3 credits) Module 2 (3 credits) Module 3 (3 credits) DAY 20 Without written confirmation, R2T4 is required

Quick Quiz 2: 1. Harry is enrolled in a program that offers courses in a modular format, as well as courses that span the entire term. Each one of Harry’s courses covers the 18-week trimester. Is his program offered in modules?  Yes, the program is offered in modules  No, the program is not offered in modules 2. What are the three questions a financial aid administrator should ask when determining if a student has withdrawn from a program offered in modules? Page 21

Learning Activity: Exercise—Ineda Goodwon Page 22

Learning Activity: Exercise—Ineda Goodwon
Review the scenarios described on page 22. Using the schedule below, and the decision tree, “Determining Whether or Not a Student Has Withdrawn From a Program Offered in Modules,” on page 30, determine the answers to the questions for each scenario. Quarter 1 Record your answers on page 22. Page 22

   Learning Activity: Exercise—Ineda Goodwon
Scenario A: Ineda attends Module 1 and then ceases attending Module 2 after completing just three days. She does not confirm attendance in a later module, and she does not attend Modules 3 and 4. Is Ineda enrolled in a program offered in modules?  Yes  No Is Ineda considered a withdrawal in this scenario? Is the school required to perform a R2T4 calculation?    Page 22

   Learning Activity: Exercise—Ineda Goodwon
Scenario B: Ineda attends Module 1 and then ceases attending Module 2 after completing just three days. At that time, she provides written confirmation that she still intends to attend Modules 3 and 4, as originally planned. Is Ineda considered a withdrawal in this scenario?  Yes  No Is the school required to perform a R2T4 calculation? Is R2T4 required if she confirms, but does not begin attendance in the third and fourth modules?    Page 22

Learning Activity: Interview Page 23

Learning Activity: Interview
1. Does your institution have programs offered in modules? Which ones? 2. If your institution has modular programs, what challenges have been encountered in relation to return of Title IV funds processing and calculations? 3. If your institution has modular programs, what is the student’s process for confirming attendance in a future module upon deciding to withdraw from a current module? Page 23

Student is Unable to Begin Withdrawal Process
Circumstances beyond the student’s control may prevent official withdrawal May use date the circumstance occurred, if school is not required to take attendance

Rescinding Official Withdrawal Notice
If rescinding notice, it must: Be in writing Indicate student will finish payment period or period of enrollment Subsequently withdraws, withdrawal date is: First notification of his intent Date began process Last date of an academically-related activity

Fails to Earn a Passing Grade in Any Course
Applies to schools not required to take attendance Must be able to determine if student actually completed payment period Considered an unofficial withdrawal if: Fails to earn a passing grade in any course Cannot document requirements for one course completed

Leave of Absence A temporary interruption of student’s studies
Does not include: Nonattendance during a scheduled break Situations addressed by incomplete courses Formal policy not required If formal policy exists, must meet regulatory requirements

1. Does your school have a formal, written leave of absence (LOA) policy? If so, how does it compare to the requirements of a Title IV approved LOA? 2. If a student notifies the school that she is withdrawing or begins the school’s official withdrawal process, but later decides not to withdraw, the student may rescind the withdrawal. How is this accomplished at your school? 3. How does your school determine that a student, who receives a failing grade in all of his courses for an enrollment period, actually completed that period? Describe the process. Page 29

Lesson 3: Return of Title IV Funds Formula

Determine the Percentage of Period Completed
Step 1 Determine the Percentage of Period Completed Earned a portion of aid Title IV aid is earned based on percentage of period completed Calculation of percentage completed is the only difference between credit-hour and clock-hour programs Earned all aid 60% %

Step 1 Determine the Percentage of Period Completed Credit-hour % Completed Days attended Days in period Clock-hour % Completed Scheduled hours at withdrawal Hours in period

Step 1 Determine the Percentage of Period Completed Nonterm credit-hour programs Last day may depend on individual student program progression Number of days in payment period depends on whether or not the program is self-paced

Step 1 Determine the Percentage of Period Completed Modular programs Only include completed days in numerator Include only the number of days the student was scheduled to attend in the denominator Exclude days from denominator under certain circumstances

Learning Activity: Determine the Percentage Earned Page 40

Learning Activity: Determine the Percentage Earned
Review the scenarios described on pages Using the calendars for 2017 and 2018 on pages 42-43, determine the percentage of period completed for each student. Record your answers on pages Pages 40-41

22.5% Learning Activity: Determine the Percentage Earned
Chrystal, a Title IV aid recipient, enrolls for 15 credit hours spring semester. The dates of the spring semester are 1/2/18 through 5/1/18. The semester includes a spring break that begins February 24 and ends March 4; classes resume March 5. In January, Chrystal missed two weeks of classes due to illness. Feeling over-whelmed by all the coursework she must make up, she officially withdraws on 1/26/18. Percentage completed? 22.5% 25 days attended 111 days in semester = X 100 Page 40

50% Learning Activity: Determine the Percentage Earned
Logan, a Title IV aid recipient, enrolls for 12 credit hours fall semester. The dates of the fall semester are 8/21/17 through 12/1/17, with a break between 11/22 and 11/26; classes resume 11/27. On 9/8, Logan stopped going to classes. He did not tell the school he withdrew or moved out. On 1/3/18, the school determined Logan left during the fall, after beginning attendance, and sets his withdrawal date at the midpoint of the semester, 10/8. Percentage completed? 50% Logan unofficially withdrew, so his school sets his withdrawal date at the midpoint of the semester. Page 40

Magdalene, a Title IV aid recipient, began a 900 clock-hour program on 1/2/18. On 2/16/18 (her last day of attendance), Magdalene withdrew to take a job in another state. She completed 150 clock hours. She was scheduled to complete 200 clock hours during her first payment period, which consisted of 450 clock hours. Percentage completed? 44.4% 200 clock hours 450 clock hours = X 100 Page 40

Anthony, a Title IV aid recipient, enrolls for six credit hours during the 8-week summer session. The summer session (6/4-7/27/18) contains two modules that are 4 weeks each, without scheduled breaks of five days or longer. The first module is 6/4-6/29/18. The second module is 7/2-7/27/18. Anthony enrolled in 3 credits in the first module and 3 credit hours in the second. He withdrew from all classes on 6/22/18, without written confirmation of future attendance. Percentage completed? 35.2% 19 days attended 54 days in period = X 100 Page 41

Determine the Amount of Earned Aid
Step 2 Determine the Amount of Earned Aid Total aid x % completed = Earned aid

Disbursed Aid versus Aid That Could Have Been Disbursed
Both used in the R2T4 calculation as a snapshot of student eligibility Modules Must recalculate eligibility for the Federal Pell Grant and campus-based funds Do not recalculate eligibility for Direct Loans Aid that could have been disbursed consists of undisbursed aid the student is eligible for

Learning Activity: Calculating Earned Aid Page 46

Learning Activity: Calculating Earned Aid
For the case study of “Ahmed” described on page 46, use the information provided to determine this student’s earned aid, for the purposes of the return of Title IV funds calculation. You have all the information you need on page 46. You also may choose to use the blank R2T4 Worksheet (Steps 1 and 3) on page 56. Page 46

3,960 1,733 20 1,139 Page 46

2,960 3,960 3,960 1,000 3,960 3,960 3,960 1,733 3,960 1,733 1,733 5,693 Page 46

20 5,693 1,139 Page 46

Quick Quiz 1: 1. Why is including aid that could have been disbursed a benefit to the student when doing a return of Title IV funds calculation? 2. What is the institution’s responsibility once it has determined a student has withdrawn? 3. What is the rounding rule when calculating earned aid? Page 47

Determine the Amount of Unearned Aid
Step 3 Determine the Amount of Unearned Aid Disbursed aid – Earned aid = Unearned aid

Determine the School and Student Shares
Step 4 Determine the School and Student Shares School’s share Lesser of the total amount of unearned aid or amount equal to institutional charges multiplied by percentage earned Student’s share Difference between unearned aid and the school’s share

Allocate Unearned Aid Federal Loans Federal Grants Step 5
Direct Unsubsidized Direct Subsidized Federal Perkins Loan Federal PLUS Federal Pell Grant FSEOG TEACH Grant IASG

Learning Activity: Allocating Unearned Aid Page 50

Learning Activity: Allocating Unearned Aid
For the case study of “Sophia” described on page 50, use the information provided to determine this student’s earned aid, for the purposes of the return of Title IV funds calculation. You have all the information you need on page 50. You also may choose to use the blank R2T4 Worksheet (Steps 1, 3, 4, and 6-10) on pages Page 50

485 1,000 1,485 50 743 912 (student) 743 grant protection 169 169 Federal Pell Grant Page 46

485 1,485 3,818 5,303 1,000 1,485 1,485 1,485 1,095 2,723 1,485 3,818 3,818 5,303 Page 46

7.2 5,303 381 5,303 381 4,922 Page 46

1,095 2,723 3,818 192 Page 46

4,922 4,010 912 3,818 3,818 Page 46

912 912 169 1,485 743 912 743 169 Page 46

Quick Quiz 2: 1. What is the equation to figure out how much of a student’s aid is unearned? 2. What is the order (of programs) in which aid is returned? 3. What is the de minimis Title IV grant amount for a student? Page 51

Returning Unearned Aid
School 45 days from date of determination Student or Parent Loan funds are repaid according to promissory note Student Grant fund repayment options

Other Considerations Use of payment period or period of enrollment
Prorating institutional charges Treatment of Title IV Credit Balances Date of determination

Why do you think return of Title IV funds calculations are necessary?
Is your institution one that requires attendance be taken? What do you think the benefits may be to students if a school takes attendance? Page 55

Lesson 4: Post-Withdrawal Disbursements and Timeframes

Title IV Funds Formula: Earned Aid Exceeds Disbursed Aid
Step 1 Determine the Percentage of Period Completed Determine the Amount of Earned Aid Determine the Amount of the Post-Withdrawal Disbursement Step 2 Step 3

Title IV Funds Which Cannot Be Included
Title IV Grants Direct Loans Federal Perkins Loans

Quick Quiz 1: 1. As a benefit to the student, what is also considered along with disbursed aid when calculating earned aid?  Post-withdrawal disbursements  Aid that could have been disbursed  Aid that the school can never disburse 2. For clock-hour programs, only _____________ hours are used in the calculation. 3. What Title IV loans cannot be included in a post-withdrawal disbursement? 4. What is the institution’s responsibility in regard to post-withdrawal disbursements? Page 72

Credit Unpaid Charges Crediting student account Requirements
Step 4 Credit Unpaid Charges Crediting student account May credit grant funds May not loan funds without borrower confirmation Requirements Disbursement notification Authorization requirements Other cash management restrictions

Offering Any Portion Not Credited to Institutional Charges
Step 5 Offering Any Portion Not Credited to Institutional Charges School must directly disburse to the student any amount of a post-withdrawal disbursement of grant funds not credited to the student’s account Requirements Disbursement notification

Why do you think the regulations give schools the flexibility to allow students to have the post-withdrawal disbursement after the original deadline set by the school? Do you agree or disagree with the regulations? How are post-withdrawal disbursement notices forwarded to the student and/or the parent borrower? Is it done via postal mail, , or by some other means? Why does your institution use this method and in what ways is it effective? Are there ways that your school may tweak its notification process? Page 76

Timeframes Notifications Aid student must repay
School’s return of funds Post-withdrawal disbursements Verification

Quick Quiz 2: 1. The mix of ________________ and _________________ aid cannot be altered after a student has withdrawn. 2. What charges can be covered by a post-withdrawal disbursement without student or parent PLUS borrower approval?  Current award year charges for tuition  Current award year charges for fees  Prior year charges $200 or less for tuition, fees, room or board  All of the above Page 79

Quick Quiz 2: 3. A notification offering a post-withdrawal disbursement should include a _____________ that the borrower wants the Title IV funds. 4. How long does a student have to pay a Title IV grant overpayment?  45 days  30 days  180 days  240 days Page 79

1. Is your school subject to the 30-day delayed disbursement for first-year, first-time borrowers? Does this affect your post-withdrawal disbursements? How? 2. How does your school handle students who have an outstanding balance and may be eligible for a post-withdrawal disbursement, but have not submitted all documentation for verification? Do you reach out to these students? Do the students continue to receive notifications to submit documents for verification? 3. May students set up a payment plan for satisfying overpayments directly with the school or must that process be handled with ED? Page 80

Return of Title IV Funds A NASFAA Authorized Event Presented by [Name of Presenter/Association] [Location] [Date], 2017.

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