1. R2T4 for Modular Based Programs

2. Let’s Not Assume – so A QUICK REVIEW OF THE BASICS
Withdrawal
Student ceased attendance in all classes during payment period/period of enrollment
Title IV Recipient
Received federal grant or loan funds or
Meets the requirements to receive a late disbursement of federal loan funds
Title IV Aid
Not all TIV programs are subject to R2T4

3. 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

4. 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
The Federal Government was in that business prior to R2T4
THE PROPOSER ACT WOULD PUT THEM BACK INTO THAT BUSINESS

5. Required to Take Attendance or Not 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

6. If Not Required to Take Attendance
Withdrawal date depends on whether the student is an:
Official withdrawal
Unofficial withdrawal
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
Time frame for determination

7. Modules Defined
668.22(i) (6)
“when a course or courses in program do not span entire length of payment period(term) or period of enrollment’
Doesn’t matter what modules are called at the institution
E.g, mini-terms, J-terms, mini-mesters, mini-sessions

8. Modules: Changing Patterns in Education
Short term and sequential course enrollment
courses are often offered in modules, usually 1-8 weeks in length
Programs with modules may –
compose an entire program; or
be offered in conjunction with courses that span the full term

9. Modules: Changing Patterns in Education
Used in Standard Term, Non-Standard Term and Non-Term Settings
May have two or more modules within a term
May be sequential or concurrent
May overlap

10. What do Modules Look Like?
SEMESTER

11. What do Modules Look Like?
SEMESTER
Module A
Module B

12. What do Modules Look Like?
SEMESTER
Module B
Module A

13. What do Modules Look Like?
SEMESTER
Module C
Module D
Module E

14. What do Modules Look Like?
SEMESTER
Module A
Module B
Module C
Module D
Module E
Module F
Module G
Module H

15. Withdrawal from Programs Offered in Modules
A withdrawal occurs when student:
Ceases attendance before completion of payment period as scheduled, AND
No written confirmation of future attendance provided

16. Withdrawal Defined
Student does not complete all days scheduled to complete within the payment period/term (whether official or unofficial withdrawal)
If no passing grade in last scheduled course/module, school must demonstrate student completed period

17. Withdrawal Defined
An administrative withdrawal initiated by the school is considered an official withdrawal
A school may drop a student from a class in a future module because the student failed a prerequisite class in a prior module

18. Calendar Days- Credit Hour Modules
Total calendar days include all days in which the student was scheduled to attend
Days of attendance in courses count regardless of whether module(s) were completed
Exclude scheduled breaks of at least 5 consecutive days when student is not scheduled to attend a module or other course
Includes allowable breaks between modules (as long as not attending other courses during the break)
When a student who has made schedule changes withdraws, do not count attendance in courses officially dropped prior to ceasing attendance

19. Impact of Enrollment Status Changes
Adjustments to a student’s enrollment status made after a student has ceased attendance have no bearing on the R2T4 calculations
If a student enrolled in 3 modules, completes one, and then drops the remaining two after ceasing attendance, all days in all three modules will be included in the R2T4 calculation
This can apply to situations where a student drops all future modules during a break between modules

20. Impact of Enrollment Status Changes
If a student drops all future courses on the same day they withdraw from a current module it is considered a withdrawal and all days in all modules the student was scheduled to attend must be included in the R2T4 calculation
Update: If drop future courses on LAST DAY of module completed, future courses are not factored into R2T4
Considered dropped while attending other courses

21. R2T4 and Pell Grant Recalculation
Student doesn’t begin attendance in all classes in a term
If a student does not begin attendance in all of his or her classes, resulting in a change in the student’s enrollment status, your school must recalculate the student’s award based on the lower enrollment status
If a school learns a student did not begin attendance in all courses and an R2T4 calculation is required, FIRST perform the Pell recalculation and then include the adjusted Pell amount in the R2T4 calculation
The Pell recalculation is a separate and distinct process from the R2T4 calculation

22. Withdrawal from a Program Offered in Modules
Q: How do I know when a student has withdrawn in a program offered using modules? A: Use the following flowchart (also refer to decision tree handout):

24. Before we do a deep dive a look at the Hybrid Model
SEMESTER
Module A
Module B
Remember – if a student is still in attendance while withdrawing from a module – there is no R2T4
In this example a student is taking two 15 week courses and one course in Mod A and one in Mod B.
Student then, after completing Module A (during 1 week break) drops module B - R2T4 is not required.
REASON = Student is still attending the 2 courses in the 15 week semester
Pell grant would have to be adjusted from FT to Three Quarter Time

25. Withdrawal from a Program Offered in Modules
A student enrolled in a credit-hour program is considered to have withdrawn* if the student does not complete all the days in the payment period or period of enrollment that he or she was scheduled to complete.
This includes cases where a student completes a module, but does not drop out of a future module that he or she was scheduled to attend.
*Unless the student provides written confirmation that he or she intends to return in a future module under certain circumstances

26. Withdrawal from a Program Offered in Modules
A student who drops all future classes between modules he or she was scheduled to attend is considered to have withdrawn.
NOTE: If a student drops all future classes in a payment period or period of enrollment on the same day the student completes a module, or prior to completing the module, the student is not considered a withdrawal.

27. Withdrawal from a Program Offered in Modules
The denominator of the Return of Title IV (R2T4) calculation is the total number of calendar days in the payment period or period of enrollment, including all days within the period that the student was scheduled to complete prior to ceasing attendance.
Excludes scheduled breaks of at least five consecutive days when the student is not scheduled to attend a module or other course offered during that period of time

28. Withdrawal from a Program Offered in Modules
Therefore, for a student who is scheduled to complete more than one module:
If the student withdraws from or completes a module and later drops all classes in the future module(s), the total number of calendar days in the denominator will include the days in the future module(s)
If the student drops the future module(s) prior to withdrawing, the total number of calendar days in the denominator will NOT include the days in the future module(s)

29. Withdrawal from a Program Offered in Modules: Example 1
Break
Module 2
Steve is scheduled for classes in both Modules 1 and 2
He completes Module 1, but never returns for Module 2 and does not inform the school that he is leaving
The student is considered withdrawn when he does not return to Module 2, and the denominator of his R2T4 calculation will include all the days in Modules 1 and 2
Pell must be recalculated using only classes attended in Module 1 and only the recalculated amount is included in the R2T4 calculation
Completes Module 1
Does not return to attend Module 2

30. Withdrawal from a Program Offered in Modules: Example 2
Break
Module 2
Lisa is scheduled for classes in both Modules 1 and 2
She completes Module 1, and subsequently drops all of her courses in Module 2 during the break
The student is considered withdrawn when she drops all the courses in Module 2, and the denominator of her R2T4 calculation will include all the days in Modules 1 and 2
Pell must be recalculated using only classes attended in Module 1 and only the recalculated amount is included in the R2T4 calculation
Completes Module 1
Drops all courses in Module 2

31. Withdrawal from a Program Offered in Modules: Example 3
Break
Module 2
Howard is scheduled for classes in both Modules 1 and 2
Three weeks before the end of Module 1, he drops all courses in Module 2. Then he completes Module 1
The student is considered to have completed the period because he was not scheduled to attend other courses when he ceased attendance. No R2T4 calculation is required
Pell must be recalculated using only classes attended in Module 1
Howard was smart!
Drops all courses in Module 2
Completes Module 1

32. Withdrawal from a Program Offered in Modules: Example 4
Break
Module 2
Greg is scheduled for classes in both Modules 1 and 2
Three weeks into Module 1, she drops all of her courses in Module 2. Then, two weeks later, he withdraws from Module 1
The student is considered withdrawn when he drops his classes in Module 1. The denominator of his R2T4 calculation will include only the days in Module 1
Pell must be recalculated using only classes attended in Module 1 and only the recalculated amount is included in the R2T4 calculation
Drops all courses in Module 2
Withdraws from Module 1

33. Returning After Withdrawal
If a withdrawn student returns to the school within the same payment period or period of enrollment for a term-based program offered in modules, the student is treated as though he or she did not cease attendance and the school must “undo” the R2T4 calculation.
Note: If the school awarded Pell Grant funds on the basis of classes the student did not attend, the school must recalculate the student’s Pell Grant.

34. Returning After Withdrawal: Example
Module 1
Module 2
Module 3
Withdraws on Day 40
Anthony enrolls for 3 modules within a semester, each 35 days in length, and with a week in between Modules 1 & 2 and 2 & 3. He enrolls in 3 credits in Module 1, 6 credits in Module 2, and 3 credits in Module 3, so he is considered enrolled full-time. He receives $2,000 in Pell Grant funds and $3,500 in Direct Loan funds.
Anthony begins Module 1, but then decides to withdraw on Day 40. On that day, Anthony drops Modules 1 and 2. He does not drop Module 3, but he also does not actively confirm that he will return.

35. Returning After Withdrawal: Example
Module 1
Module 2
Module 3
Withdraws on Day 40
The school considers Sandra to be withdrawn. First, the school recalculates Sandra’s Pell Grant to include only the credits in Module 1, which was the only module he attended. This recalculation results in a less-than-half-time enrollment status.
The school includes the less-than-half-time Pell Grant disbursement ($500) in the R2T4 calculation and returns the remaining $1,500 in Pell. The R2T4 calculation requires the return of $2,000 of Sandra’s Direct Loan, and the school promptly makes the return.

36. Returning After Withdrawal: Example
Module 1
Module 2
Module 3
Returns
Sandra returns unexpectedly in Module 3, which is in the same payment period as Module 1.
The school then reinstates her Title IV aid, re-disbursing the $2,000 in Direct Loan funds that were returned. However, because Sandra did not attend Module 2, the school again recalculates his Pell Grant enrollment status, this time to half-time. The school disburses an additional $500 in Pell Grant funds for a total of $1,000 for the semester.

37. Written Confirmation
For programs offered in modules, a student is NOT considered to have withdrawn if:
For standard term programs, the institution obtains written confirmation that the student will return to attend a Title IV-eligible course within the same payment period or period of enrollment
For non-term and nonstandard term programs, the institution obtains written confirmation AND the module the student is expected to attend begins no later than 45 calendar days after the end of the module the student ceased attendance

38. Written Confirmation
An online confirmation of future attendance from the student can constitute written confirmation if the confirmation is a timely positive confirmation of future attendance and occurs after the withdrawal.
A student can revise the date of return to a later module if the student does so in writing after the time of the withdrawal but prior to the return date.

39. Written Confirmation: Failure to Return
If a school obtains a written confirmation of future attendance but the student does not return as scheduled, the student is considered to have withdrawn from the payment period or period of enrollment.
In that case, the student’s withdrawal date and the total number of calendar days in the period are the same as those that would have applied if the student had not provided written confirmation of future attendance.

40. Example: Vera 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

41. Example: Vera Enrolled in 15-week semester
Ceases attending classes on Day 20 of first module
Vera does provide written confirmation to return in module
If Vera does return her Pell is adjusted to half time
Module 1 (3 credits)
Module 2 (3 credits)
Module 3 (3 credits)
DAY 20
With written confirmation, R2T4 is not required

42. Example: Vera Enrolled in 15-week semester
Ceases attending classes on Day 20 of first module
Vera does provide written confirmation to return in module
If Vera does not return her Pell is adjusted to less than half time
Module 1 (3 credits)
Module 2 (3 credits)
Module 3 (3 credits)
DAY 20
The R2T4 is required – the loans do not need to be returned in full, unless R2T4 requires it because she was eligible for it upon disbursement. R2T4 formula is 20/# of days in mod 1

43. You get more answers with with honey than….

44. Contact Information
Howard Leslie, MS Vice President, Financial Aid Berkeley College. Gregory M. Rinderle Director, McClintock & Associates, P.C