1. RETURN OF TITLE IV FUNDS Vicki Kucera November 1, 2013 NeASFAA Support Staff Workshop

2. WHY??  To determine the amount of unearned funds that must be returned to Title IV programs: By whom? Within what time frame?

3. REQUIREMENTS  Amount of earned Title IV aid is proportionate to portion of period completed at the time the student withdrew.  Unearned Title IV aid must be returned.  Undisbursed earned Title IV aid must be disbursed or offered.

4. R EQUIREMENTS …  Amount of unearned Title IV aid to be returned is independent of institutional charges assessed under school’s refund policy.  Title IV regulations do not govern school’s refund policy.

5. WHAT PROGRAMS ARE APPLICABLE??  Federal Pell Grant  Iraq and Afghanistan Service Grant (IASG)  Teacher Education Assistance for College and Higher Education (TEACH)  Federal Supplemental Educational Opportunity Grant (FSEOG)  Federal Perkins Loan; and  Federal Direct Student Loan (Direct Loan)

6. WHAT PROGRAMS ARE NOT APPLICABLE??  Federal Work-Study (FWS)  Non Title IV Funds  Nebraska Opportunity Grant  Scholarships  Tuition Waivers  Institutional Grants  Other

7. HOW DO WE CALCULATE ROT4 IF STUDENT NEVER STARTS ATTENDING? We don’t. If the student never starts attending any classes in a payment period, they are not eligible for ANY Title IV funds.

8. WHEN IS R0T4 APPROPRIATE?  When student withdraws 100% of coursework.  Can be written or oral.  If withdrawal is by letter from student, withdrawal date would be date school received the letter.  If oral, document date of conversation.  If student begins process on one date and officially withdraws another, use earlier date.

9. WHEN IS R0T4 APPROPRIATE?  Date of unofficial withdrawal (last date of attendance for schools required to take attendance).  Student fails to earn passing grades – school must treat the student as having unofficially withdrawn using the:  Midpoint of the payment period, or  Documented last date of attendance at an academically related activity.

10. MODULES – QUESTIONS TO ASK : 1. After beginning attendance, did student stop attending in a course he/she was scheduled to attend? 2. When student stopped attending was he still attending any other courses? 3. Did student confirm attendance in writing for enrollment in a course in a module later in the payment period or period of enrollment?

11. S TEP 1: D ETERMINE % OF AID EARNED Days Attended _______________ = Percentage completed Days in period Do not count breaks that are at least five days in length (includes weekends). Example: Student attends 71 days out of 113 days. Percentage completed: 71 divided by 113 = 62.8%

12. 60% RULE  If student attends or withdraws past the 60% point in the term, no Return of Title IV Funds.  School must still do calculation and keep on record.

13. S TEP 2: D ETERMINE AMOUNT OF AID EARNED BY APPLYING % COMPLETED TO THE TOTAL T ITLE IV AID THAT WAS OR COULD HAVE BEEN DISBURSED. Earned aid = (Disbursed aid + Aid that could have been disbursed) x % completed. NOTE: Aid that could have been disbursed includes loans. It is very appropriate to give students the option of cancelling their loan request if they are withdrawing (but not mandatory).

14. S TEP 3: D ETERMINE THE AMOUNT OF UNEARNED AID BY SUBTRACTING EARNED AID FROM DISBURSED AID  Unearned aid must be returned to the appropriate Title IV Program.

15. S TEP 4: D ISTRIBUTE RESPONSIBILITIES FOR RETURNING UNEARNED AID BETWEEN SCHOOL AND STUDENT  Formula is designed so that all funds are returned by the school if student’s institutional charges equal or exceed Title IV funds disbursed, OR  School and student each return a share of the funds if Title IV funds disbursed exceeds student’s institutional charges.  Institutional charges used in the calculation are those charges originally assessed the student or revised amount resulting from enrollment status changes pre- withdrawal.

16. STEP 5: A LLOCATE UNEARNED AID BACK TO THE T ITLE IV P ROGRAMS  Allocate unearned funds to programs in this order:  Direct Unsubsidized Loan  Direct Subsidized Loan  Federal Perkins Loan  Direct PLUS  Federal Pell Grant  FSEOG  TEACH Grant, and then  IASG

17. TIMEFRAME  School must return unearned Title IV funds for which it is responsible within 45 days of the date school determined the student withdrew.  Unearned loan funds to be returned by the student or parent PLUS borrower are repaid according to the terms of the promissory note.  If the student must repay unearned grant funds, school must notify the student that he or she has 45 days in which to repay the overpayment in full or enter into a repayment agreement with the school or US Dept. of Education.  Round repayment amounts to nearest dollar.

18. DISCUSSION!!  Reauthorization 2014 (or 2015, or 2016, or 2017…)  Special circumstances  Other