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Return of Title IV Funds Q & A | Program Integrity Q&A
Questions on this topic are
divided into the following categories:
- General Questions
- Programs Offered in Modules (Mod)
- Scheduled Days in a Payment Period for a Program Offered in Modules(SD)
- R2T4 Calculation Freeze Date (RCFD)
General Questions (R2T4)
R2T4-Q1: How does the July 1, 2011, effective date apply to the changes to the Return of Title IV Funds regulations?
R2T4-A1: The changes to §668.22, known as the Return of Title IV Funds regulations, apply to students who withdraw from payment periods or periods of enrollment that begin on or after July 1, 2011. This means that they do not apply to students who withdraw from a 2011 crossover payment period that begins prior to July 1, 2011, even if the student received Title IV, HEA program funds from the 2011-2012 award year for that crossover payment period. [Guidance issued 7/20/2011]
Programs Offered in Modules (MOD)
MOD-Q9: Section 668.22(f)(1)(i) provides that the percentage of the payment period or period of enrollment completed is determined for a credit hour program by dividing the total number of calendar days in the payment period or period of enrollment into the number of calendar days completed in that period as of the student’s withdrawal date. If a student ceases attendance in the first of three modules he or she is scheduled to attend in a payment period or period of enrollment and subsequently drops the classes in the two remaining modules prior to the beginning of module two, does the total number of calendar days in the payment period or period of enrollment include all the days in all the modules, or just the first module? What if the student drops the classes in the two remaining modules prior to ceasing attendance in the first module?
MOD-A9: The total number of calendar days in the period includes all days within the period that the student was scheduled to complete prior to ceasing attendance, excluding days in which the student was on an approved leave of absence and any 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. Adjustments to a student enrollment status made after the student ceases attendance have no bearing on the Return of Title IV Funds requirements. Thus, if the student drops the classes in the two remaining modules after ceasing attendance, the total number of calendar days in this student’s payment period or period of enrollment would include the days in all three modules, except for any 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, and days in which the student was on an approved leave of absence. However, if the student drops the classes in the two remaining modules prior to ceasing attendance (which would necessitate a recalculation of the student’s eligibility for Title IV, HEA program funds), the total number of calendar days in the student’s payment period or period of enrollment would include only the days in the first module, except for any scheduled breaks of at least five consecutive days and days in which the student was on an approved leave of absence. [Guidance issued 7/20/2011]
MOD-Example—Program Offered in Modules
Provided here is an example illustrating many of the changes to the regulations addressing withdrawals from programs offered in modules. More detailed examples will be provided in the 2011-2012 Federal Student Aid Handbook.
Determination of Withdrawal Questions
As noted on page 66895 of the preamble to the final regulations, the following three questions may be used to determine whether a student in a program offered in modules is a withdrawal and the Return of Title IV Funds requirements apply:
Question 1: After beginning attendance in the payment period or period of enrollment, did the student cease to attend or fail to begin attendance in a course he or she was scheduled to attend?
If the answer is no, this is not a withdrawal. If the answer is yes, go to question 2.
Question 2: When the student ceased to attend or failed to begin attendance in a course he or she was scheduled to attend, was the student still attending any other courses?
If the answer is yes, this is not a withdrawal, however other regulatory provisions concerning recalculation may apply. If the answer is no, go to question 3.
Question 3: Did the student confirm attendance in a course in a module beginning later in the period (for non-term and nonstandard term programs, this must be no later than 45 calendar days after the end of the module the student ceased attending)?
If the answer is yes, this is not a withdrawal, unless the student does not return. If the answer is no, this is a withdrawal and the Return of Title IV Funds requirements apply.
Example
This example illustrates: (1) how to determine when a student is a withdrawal from a term-based program offered in modules; (2) the amount of aid to use in the Return of Title IV Funds calculation when a student withdraws from a program offered in modules; (3) how to determine the numerator and denominator when calculating the percentage of the payment period completed for a student who withdraws from a program offered in modules; and (4) what steps must be taken when a student who withdrew from a term-based program offered in modules returns within the payment period; (5) how to determine the numerator and denominator when calculating the percentage of the payment period completed for a student who withdraws again.
Program Profile: Payment Period/Period of Enrollment: Payment period, 15-week semester
Program structure for payment period/period of enrollment: Three consecutive five-week modules, 35 days in each module, no scheduled breaks
A student enrolls for one three-credit course in each of the three modules. Student ceases attending module 1 after completing 10 days. The student does not confirm attendance in a later module. The student does not attend module 2, but returns for the one 3-credit course in module 3. The student withdraws from module 3 after completing 15 days.
When the institution determines that the student has ceased to attend module 1, the institution answers the Determination of Withdrawal Questions to determine whether the student is a withdrawal as follows:
The answer to Question 1 is yes. The student ceased to attend a course the student was scheduled to attend—the three-credit course in module 1. Because the answer to Question 1 is yes, Question 2 must be answered.
The answer to this Question 3 is no. The student did not confirm attendance in a later module. Thus, this student is a withdrawal and the Return of Title IV Funds requirements apply.
If the student was awarded Pell Grant funds, before performing the Return of Title IV Funds calculation, the institution must recalculate the student’s awards to reflect the change in enrollment status from nine credit hours, to three credit hours. These recalculated aid amounts are used in the Return of Title IV Funds calculation.
The percentage of the payment period completed is determined by dividing the number of calendar days completed by the total number of calendar days in the payment period, which included all days within the period that the student was scheduled to complete, except for any 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, and any days the student was on an approved leave of absence. The student has completed 10 days. The total number of days in the payment period includes all the days in all the modules the student was scheduled to complete, which is 105 days (three modules of 35 days each). The percentage of the payment period completed is determined by dividing 10 days by 105 days, resulting in .0952, rounded to .095 or 9.50 percent.
When the student returns for module 3, §668.22(a)(2)(iii)(A) applies, which provides that, if a student withdraws from a term-based credit hour program offered in modules and reenters the same program prior to the end of the period, the student is treated as if he or she did not cease attendance for purposes of determining the student’s aid awards for the period. The student is considered to be in the same payment period he or she was in at the time of the withdrawal and retains his or her original Title IV eligibility for that payment period, provided the student’s enrollment status continues to support the same amount of those funds. To do this, the institution must:
recalculate the student’s Title IV, HEA program eligibility based upon enrollment in modules 1 and 3 and then re-disburse any Title IV, HEA program funds that had been disbursed and then returned under the Return of Title IV Funds provisions, adjusting, if necessary, for the change in enrollment status from nine credit hours to six credit hours;
disburse any Title IV, HEA program funds the student was otherwise eligible for that had not yet been disbursed at the time the student withdrew, adjusting for the change in enrollment status; and
cancel any Title IV overpayments assessed the student as a result of the prior withdrawal that were disbursed upon reentry.
When the institution determines that the student has ceased to attend module 3, the institution again answers the Determination of Withdrawal Questions to determine whether the student is a withdrawal:
The answer to Question 1 is yes. The student ceased to attend a course the student was scheduled to attend—the three-credit course in module 3. Because the answer to Question 1 is yes, Question 2 must be answered.
The answer to this Question 3 is no. There are no later modules in which the student can confirm attendance. Thus, this student is a withdrawal and the Return of Title IV Funds requirements apply.
The total number of days in the payment period is the original 105 days. While the student did not begin module 2, since module 2 was included in the original payment period or period of enrollment and used to determine the amount of Title IV, HEA funds eligibility, the 35 days from module 2 are included in the denominator.
The total number of completed calendar days in the period reflects the completed days in both modules 1 and 3. The student had completed 10 days in module 1 and 15 days in module 3 for a total of 25 days completed in the payment period. The percentage of the payment period completed is determined by dividing 25 days by 105 days, resulting in .238, or 23.8 percent. [Guidance issued 7/20/2011]
MOD-Q14: If a student who is scheduled to attend all three modules in a payment period or period of enrollment drops the classes in the two remaining modules in the period between the first and second module (when the student is not attending any classes), are the days in modules two and three included in the total number of calendar days in the payment period or period of enrollment?
MOD-A14: Yes, the days in modules two and three are included in the total number of calendar days in the payment period or period of enrollment. This is the case whether the student ceased attendance during the first module or completed the first module. As noted in MOD-Q&A8, a student who ceases attendance between modules he or she is scheduled to attend is considered to have withdrawn and a Return of Title IV Funds calculation is required unless the student provides written confirmation of future attendance in the payment period or period of enrollment. However, as noted in MOD-Q&A9, adjustment to a student’s enrollment status made after the student ceases attendance have no bearing on the Return of Title IV Funds requirements. Thus, if a student drops all future classes he or she was scheduled to attend in the period between modules when the student is attending no other classes, the institution must perform a Return of Title IV Funds calculation that uses the days in all three modules for the period of enrollment unless the student provides written confirmation of future attendance in the payment period or period of enrollment. This is the case even if the class or classes are dropped by the institution, rather than the student, during the period between modules (for example, because the institution cancels the class or drops the student from the class because it determines that the student’s grades in prior classes do not allow the student to progress to that class). [Guidance issued 2/2/2012]
MOD-Q15: If a student (or an institution) drops classes on the same day that the student withdraws, is the student's enrollment status adjusted to reflect the dropped classes for Return of Title IV Funds purposes?
MOD-A15: No. Classes dropped on the same day that the student withdraws have no bearing on the Return of Title IV Funds requirements. The institution must perform a Return of Title IV Funds calculation that includes those classes in the days in all modules the student was scheduled to attend. [Guidance issued 2/2/2012]
MOD-Q18: A student met the conditions for a withdrawal exemption through successful completion of coursework, but later ceased attendance in other coursework during the payment period or period of enrollment. At the time that the student ceased attendance, the institution had not disbursed all of the Pell Grant and Direct Loan funds for which the student was otherwise eligible. In this situation, is the institution permitted to disburse any remaining amounts of Pell or Direct Loan funds?
MOD-A18: When a student meets the conditions for a withdrawal exemption, the student is treated as having completed the payment period and, for purposes of the Title IV programs, is considered enrolled through the end of the period even if the student later stops attending future coursework or modules in that period. In that situation, if the student had not received all of their Pell Grant or Direct Loan disbursements for the payment period, it is possible for the student to receive additional disbursements during the payment period depending on specific Title IV program requirements and the Department’s cash management requirements.
For Pell Grant purposes, the institution must determine whether the student is subject to a mandatory Pell recalculation because the student did not begin all classes that comprised the student’s Pell Grant enrollment status for the period. Additionally, the institution must disburse any remaining Pell Grant funds for which the student is eligible before the end of the payment period. If the institution fails to disburse all of the Pell Grant funds for which the student is eligible until after the payment period is over, a subsequent disbursement of Pell Grant funds for the period is treated as a retroactive or late disbursement that is subject to all requirements for such disbursements, including the requirement under 34 CFR 690.76(b) that the student’s Pell Grant enrollment status must be determined according to work already completed.
For Direct Loan purposes, when a student ceases attendance during a payment period after meeting the conditions for a withdrawal exemption, the institution must disburse Direct Loan funds for which a student is eligible during the payment period only if the student is enrolled at least half time at the time of disbursement. If the student ceased attendance prior to attending coursework that comprised at least half-time enrollment, it is impossible for that student to enroll half-time during the period unless the student resumes attendance later in the period. Therefore, in this situation the institution cannot make the Direct Loan disbursement unless it confirms that the student commenced attendance in coursework that comprises at least half-time attendance during the payment period. If the institution fails to make the disbursement of Direct Loan funds until after the payment period is over, the disbursement is treated as a retroactive or late disbursement that is subject to all requirements for such disbursements, including the requirement that the student has completed coursework comprising half-time enrollment during the period.
As an example, consider a student who enrolls in two eight-week modules within a payment period. The student enrolls in one three-credit class in each module for a total of six hours, which meets the institution’s definition of half-time enrollment. The student is awarded Pell Grant and Direct Loans, but due to administrative delays the institution is unable to make the Title IV disbursements while the student is still in attendance.
As of the institution’s Pell recalculation date the student is enrolled half time. The student successfully completes the first module and meets the conditions for a withdrawal exemption. The student then begins the second module, but ceases attendance prior to receiving any Title IV disbursements for the period. The student is considered a completer and, for Title IV purposes, remains enrolled throughout the entire payment period.
The student qualifies for a Pell Grant disbursement at half-time enrollment status because the student was enrolled half-time on the Pell recalculation date and the student began attendance in coursework sufficient to comprise half-time enrollment. For Direct Loan purposes, the student was enrolled half-time and had begun attendance in coursework that comprised half-time enrollment at the time the student ceased attendance. Therefore, the institution must disburse the Direct Loan funds for which the student is eligible during the payment period.
This scenario would change significantly if, after completing the first module, the student never began attendance in the second module. In that case, since the student never began attendance in coursework sufficient for half-time enrollment, the student would be subject to a mandatory Pell Grant recalculation and would only qualify for a less-than-half-time Pell Grant disbursement. In this circumstance, the student would also be ineligible to receive Direct Loan funds for the period because the student never commenced attendance in coursework comprising half-time enrollment. [Guidance issued 08/20/2021]
Scheduled Days in a Payment Period for a Program Offered in Modules (SD)
SD-Q2: How does an institution determine whether the days in a module are included in the R2T4 calculation? Are there differences based on whether the institution uses an R2T4 Freeze Date?
SD-A2: The answer depends on whether the institution uses an R2T4 Freeze Date (see RCFD-A1 for additional explanation of the R2T4 Freeze Date) and the type(s) of Title IV aid for which the student is eligible during the payment period or period of enrollment.
If the institution uses an R2T4 Freeze Date, the days in a module are included in the R2T4 calculation if the student attends the module or is enrolled in the module on the R2T4 Freeze Date.
If the student is only eligible for Pell Grant, Iraq-Afghanistan Service Grant, and/or TEACH Grant funds during the period and the institution does NOT use an R2T4 Freeze Date, the days in a module must be included in the denominator of the R2T4 calculation only if the student actually attends the module. This is because Pell Grant, Iraq-Afghanistan Service Grant, and TEACH Grant recalculation requirements ultimately require institutions to exclude from consideration in the student's enrollment status any coursework that the student did not attend.
If the student is eligible for Direct Loan or FSEOG funds during the period (regardless of eligibility for other Title IV programs) and does NOT use an R2T4 Freeze Date, the days in a module must be included in the R2T4 calculation if the student enrolled in the module at any time during the period. This is because a student's cost of attendance for these programs is affected by the student's enrollment in all modules during a payment period or period of enrollment. [Guidance issued 08/20/2021]
SD-Q2: How does an institution determine whether the days in a module are included in the R2T4 calculation? Are there differences based on whether the institution uses an R2T4 Freeze Date?
SD-A2: The answer depends on whether the institution uses an R2T4 Freeze Date (see RCFD-A1 for additional explanation of the R2T4 Freeze Date) and the type(s) of Title IV aid for which the student is eligible during the payment period or period of enrollment.
If the institution uses an R2T4 Freeze Date, the days in a module are included in the R2T4 calculation if the student attends the module or is enrolled in the module on the R2T4 Freeze Date.
If the student is only eligible for Pell Grant, Iraq-Afghanistan Service Grant, and/or TEACH Grant funds during the period and the institution does NOT use an R2T4 Freeze Date, the days in a module must be included in the denominator of the R2T4 calculation only if the student actually attends the module. This is because Pell Grant, Iraq-Afghanistan Service Grant, and TEACH Grant recalculation requirements ultimately require institutions to exclude from consideration in the student's enrollment status any coursework that the student did not attend.
If the student is eligible for Direct Loan or FSEOG funds during the period (regardless of eligibility for other Title IV programs) and does NOT use an R2T4 Freeze Date, the days in a module must be included in the R2T4 calculation if the student enrolled or registered in the module at any time for the period. This is because a student's cost of attendance for these programs is affected by the student's enrollment in all modules during a payment period or period of enrollment. [Guidance issued 08/20/2021;revised 09/03/2021]
SD-Q2: How does an institution determine whether the days in a module are included in the R2T4 calculation? Are there differences based on whether the institution uses an R2T4 Freeze Date?
SD-A2: The answer depends on whether the institution uses an R2T4 Freeze Date (see RCFD-A1 for additional explanation of the R2T4 Freeze Date) and the type(s) of Title IV aid for which the student is eligible during the payment period or period of enrollment.
When a student enrolls in a module during a payment period or period of enrollment, the following guidance applies to all courses the student enrolls in including full-term courses during the period.
If the institution uses an R2T4 Freeze Date, the days in a module/course are included in the R2T4 calculation if the student attends the module/course or is enrolled in the module/course on the R2T4 Freeze Date.
If the student is only eligible for Pell Grant, Iraq-Afghanistan Service Grant, and/or TEACH Grant funds during the period and the institution does NOT use an R2T4 Freeze Date, the days in a module/course must be included in the denominator of the R2T4 calculation only if the student actually attends the module/course. This is because Pell Grant, Iraq-Afghanistan Service Grant, and TEACH Grant recalculation requirements ultimately require institutions to exclude from consideration in the student’s enrollment status any coursework that the student did not attend.
If the student is eligible for Direct Loan or FSEOG funds during the period (regardless of eligibility for other Title IV programs) and does NOT use an R2T4 Freeze Date, the days in a module/course must be included in the R2T4 calculation if the student was enrolled in the module/course on the first day of the period or enrolled in the module/course at any time during the period. This is because a student’s cost of attendance for these programs is affected by the student’s enrollment in all modules during a payment period or period of enrollment. [Guidance issued 08/20/2021 - archived; revised 09/03/2021 - archived; revised 10/06/21]
R2T4 Calculation Freeze Date (RCFD)
RCFD-Q2: Can you apply the R2T4 Freeze Date to some students and not to other students within the same program?
RCFD-A2: No. An institutions R2T4 Freeze Date policy must be applied consistently to all students in the same program. [Guidance issued 08/20/2021]
