1. Return of Title IV Funds R2T4 NYSFAAA REGION VII PRESENTER DEBRA HANSEN STONY BROOK UNIVERSITY

2. Topics Basic Principles Payment Period or Period of Enrollment Types of Institutions Withdrawal Date (Last Date of Attendance) Institutional Determination Date Leave of Absence Aid That Could Have Been Disbursed Earned vs. Unearned

3. Basic Principles Title IV funds are awarded to a student with the assumption that the student will attend school for the entire period for which the assistance is awarded When a student ceases attendance prior to the planned ending date, the student may not be eligible for the full amount of Title IV funds the student was scheduled to receive The student ‘earns’ a percentage of the total Title IV Aid based on the percentage of the Payment Period or Period of Enrollment completed After completion of 60% of the Payment Period or Period of Enrollment student has ‘earned’ 100% of Title IV Aid

4. Basic Principles If a school has disbursed more Title IV Aid than the student earned, Title IV Aid must be returned to the programs If a school has disbursed less Title IV Aid than the student earned, a post withdrawal disbursement will be calculated and must be offered Institutional or other refund policies (State, accreditor) do not impact the amount of Title IV Aid earned under a Return of Title IV Funds (R2T4) Calculation If a student never begins attendance for a payment period or period of enrollment, the student is not eligible for Title IV Aid and the R2T4 calculation is not applicable

5. Payment Period or Period of Enrollment For a standard term based program, the institution must use the payment period For a non-term or non-standard term program, the institution may use either the payment period or period of enrollment Must use consistently for all students in a program

6. Payment Period and Period of Enrollment Payment Period Aug 19 Dec 6 Period of Enrollment Aug 19 Dec 6 Jan 13May 7

7. Payment Period or Period of Enrollment Example #1- Student leaves after 23 days in the first term of a two-term academic year Payment Period Total # of Days: 100 # of Days Completed: 23 ______ % Earned: 0.23 Total Title IV Aid: $2000 (Disbursed or Could Have Been Disbursed) ________ Amount Earned: $460 Amount Unearned: $1540 Period of Enrollment Total # of Days: 200 # of Days Completed: 23 ______ % Earned: 0.115 Total Title IV Aid: $4000 (Disbursed or Could Have Been Disbursed) ________ Amount Earned: $460 Amount Unearned: $3540

8. Payment Period or Period of Enrollment Example #2 - Student leaves after 21 days in the second term of a two-term academic year Payment Period Total # of Days: 100 # of Days Completed: 21 ______ % Earned: 0.21 Total Title IV Aid: (Disbursed or Could $2000 Have Been Disbursed) ________ Amount Earned: $420 Amount Unearned: $1580 Period of Enrollment Total # of Days: 200 # of Days Completed: 121 ______ % Earned: 0.605 ( If > 60%, earned = 100% ) Total Title IV Aid: (Disbursed or Could $4000 Have Been Disbursed) ________ Amount Earned: $4000 Amount Unearned: $0

9. Institutions Required to Take Attendance Outside entity requires that attendance be taken Institution has its own requirement that instructors take attendance at the Institutional level – all faculty required to take attendance Departmental level – specific Departments have an attendance taking requirement Program level – a specific program requires attendance taking Programs measured in Clock-hour programs Outside entity or the institution has a requirement that can only be met by taking attendance If a faculty member choses to take attendance, this does not meet the definition of an institution required to take attendance Institutions required to take attendance must use official attendance records to determine last date of attendance An institution could be considered Required to Take Attendance for a subset of students Specific Programs Limited Period of Time

10. Institutions Not Required to Take Attendance Not Required to take attendance by an outside entity Most institutions fit into this category If an institution has a census date where a snapshot of attendance is taken, it does not reclassify as an institution required to take attendance If an institution has a program taught in modules there can be up to one census date in each module

11. Important Dates – Date of Determination Institutional Determination Date ◦The date the institution is made aware that the student ceased attending ◦This date is used as the date that the institution must take action ◦Within 30 days institution must ◦Perform calculation ◦Notify student of any grant overpayment ◦Notify student of post withdrawal disbursement eligibility ◦Institution must return Title IV Funds within 45 days ◦Must make PWD within 180 days

12. Important Dates – Withdrawal Date Last Date of Attendance ◦The date used to determine the earned and unearned amounts of Title IV Funds from the Return of Title IV Funds Calculation ◦Institutions required to take attendance must use attendance records to make the determination ◦For institutions not required to take attendance the last date of attendance is ◦Date student began formal withdrawal process ◦Mid-Point, if no notification given ◦Date of illness, accident, etc… ◦Beginning of LOA if student doesn’t return ◦Last date of academically related activity

13. Academic Attendance Academic attendance and attendance at an academically-related activity include: ◦Physically attending a class with direct interaction ◦Academic assignment submission ◦Taking an exam, interactive tutorial, or a computer-based instruction ◦Attending a school-assigned study group ◦Participating in an online discussion that is academically-related ◦Interacting online with faculty about subject matter or to ask course-related questions ◦An institution not required to take attendance MAY always use the last date of an academically related activity as the last date of attendance ◦The institution, NOT THE STUDENT, must document that the activity is academically related and the student’s attendance at the activity

14. Academic Attendance An academically-related activity DOES NOT include: ◦Living in institutionally provided housing or participating in the meal plan ◦Logging into an online course without active participation ◦Participating in academic counseling or advisement

15. Leave of Absence – (LOA) ◦ A temporary interruption in a program of study instead of a WD ◦ Conditions for an Approved LOA ◦ Formal written policy ◦ Student followed the formal policy in requesting the LOA ◦ There must be a reasonable expectation that the student will return from the LOA ◦ The school must approve the requested LOA in accordance with its policy ◦ The student may not be charged additional institutional charges ◦ The number of days on an approved LOA cannot exceed 180 days within a 12-month period ◦ Loan recipients must be told about the effects on their grace period if they do not return ◦ For standard term or non-standard term programs – the student must resume training at the same point the student began the LOA ◦ For non-term credit-hour programs and clock-hour programs – the student does not have to resume training at the same point the student began the LOA

16. Failure to Return from a LOA Withdrawal date is - ◦At an institution not required to take attendance ◦The date the LOA began ◦At an institution required to take attendance ◦The last date of attendance (LDA) Remember – for a student on an approved LOA, Title IV loans remain in “in- school” status for the period of the LOA. When a student does not return from a LOA part or all of the grace period could be used impacting when a student will go into repayment

17. Performing the R2T4 Calculation The academic calendar should be set up Any consecutive 5 day break periods do not count in the calendar Determine the student’s withdrawal date (Last Date of Attendance) Calculate the percent of period student completed Number of days completed divided by number of days in period Determine amount of aid the student earned Multiply percentage of period completed by Total Title IV Aid (Aid that has already disbursed + Aid that could have been disbursed) Return unearned funds to Title IV programs, or disburse post withdrawal disbursement Determine Title IV overpayment if any

18. Aid That Could Have Been Disbursed Determine if aid that was not disbursed yet should be used in the calculation to determine the amount of aid the student earned Include aid if Conditions for late disbursement were met prior to the withdrawal date ED processed the ISIR/SAR with an official EFC Perkins/FSEOG- school made the award Direct Loan- school originated the loan TEACH- school originated the grant

19. No Passing Grades Unofficial Withdrawal or Not? School must have a process for determining if the student completed the period At least one passing grade No passing grade, institution must document completion of period Grading policy that differentiates between failing, completed; and failing, did not complete

20. Having Fun with Hand Calculations! R2T4 On the Web

21. Case Studies – Credit Hour Program John Doe is enrolled in a program in University A University A has two semesters of 15 weeks each in an academic year The Fall term began on August 25 and ends on December 17 There is a break of 5 consecutive days for Thanksgiving The total countable days in the payment period calendar are 110 University A is not required to take attendance John Doe began attending and notified the Office of Records that he was withdrawing from the term on September 20 The University’s liability schedule indicates that September 20 is after 100% liability John’s institutional charges are $4,000 tuition and fees He received $2865 Pell that disbursed and $3750 Direct Loan that disbursed = total disbursed $6,615

22. Case Studies – Credit Hour Program (continued) Percentage of semester completed: 27 days complete/ 110 days in term = 0.2454 or 24.54% Percentage of aid earned: Total Aid $6615 x percentage of days completed 0.2454 = $1,623.68 Aid Disbursed $6615 – Aid Earned $1,623.68 = Aid to Return $4991.32 How much is the University required to return?

23. Case Studies – Credit Hour Program (continued) Institutional charges $4,000 x percentage of term unearned 75.46% = $3018.40 unearned institutional charges School must return lower amount of either total aid to return or unearned institutional charges, therefore school responsible to return $3018.40 School is required to return loan funds before grant funds, so $3,018 will be return to Direct Loan Student is responsible to return difference of total aid to return and what the school returns, so John Doe will return $4991.32-3018.40= $1972.92 Student returns loan funds before grant funds, there is $732 loan funds remaining that the school did not return, $1972.92-732= $1,240.32 Grant funds are protected at a 50% rate when the student is required to return funds: Original Pell Grant $2,865 x 50% = $1,432 protected Since the protected amount is greater than the amount the student is required to return, no grant funds are returned and an overpayment is not reported

24. QUESTIONS? THANKS FOR ATTENDING