Program Integrity Questions and Answers - Return of Title IV Funds

Program Integrity Q&A

Questions on this topic are divided into the following categories:

In addition to the following Q&As, please see the following resources for guidance related to the Return of Title IV Funds requirements:

General Questions (R2T4)

R2T4-Q1: How does the July 1, 2011, effective date apply to the changes to the Return of Title IV Funds (R2T4) regulations?

R2T4-A1: Archived

R2T4-Q2: What is the effective date of the R2T4 provisions in the July 1, 2021 regulations if an institution decides not to early-implement those provisions?

R2T4-A2: For institutions that did not early-implement the R2T4 provisions of the regulations prior to July 1, 2021, the regulations will apply to students who withdraw or otherwise cease attendance (including by graduating) on or after July 1, 2021. [Guidance issued 08/20/2021]

Programs Offered in Modules (MOD)

MOD-Q1: If some portions of a program are offered in modules, but some are not, is the entire program considered to be offered in modules for R2T4 purposes?

MOD-A1: Section 668.22(l)(6) of the regulations effective July 1, 2021 (unless early-implemented) provides that a program is offered in modules for purposes of determining the applicability of the R2T4 requirements if the program uses a standard term or nonstandard-term academic calendar, is not a subscription-based program, and a course or courses in the program do not span the entire length of the payment period or period of enrollment. The determination of whether a program is offered in modules is made on a payment period-by-payment period or period of enrollment-by-period of enrollment basis, as appropriate, and is student specific. So, while some payment periods or periods of enrollment in a student’s program may be considered to be offered in modules, others may not. If all the courses in a program for a particular payment period or period of enrollment, as applicable, span the entire length of the period, the program is never considered to be offered in modules for that period for any student who withdraws during the period. Conversely, if none of the courses in a program for a particular payment period or period of enrollment spans the entire length of the period, the program is always considered to be offered in modules for that period for any student who withdraws during the period. If some courses in the program for a particular payment period or period of enrollment span the entire length of the period but some do not, the program is considered to be offered in modules only for those students who are scheduled to attend at least one course that does not span the entire length of the period, and withdraw during the period.

For example, an institution offers a credit hour program in semesters with two optional summer sessions. All the courses in the Fall and Spring semesters span the entire length of the semester. The two summer sessions are offered sequentially, and are both seven weeks long. The institution chooses to combine the summer sessions into one term. Students have the option to enroll in either session or both sessions. The Fall and Spring semesters are never considered to be offered in modules for any student who withdraws because all classes span the entire length of the payment period (the term). However, for the summer sessions, where the payment period is the term comprising both sessions, all students who withdraw are considered to be withdrawing from a program offered in modules (with each session being a module) because none of the courses offered spans the entire length of the payment period. If, for the summer term, the institution also offered courses that were 14 weeks in length (i.e., spanned the entire length of the payment period) and a student who withdrew was scheduled to attend only these 14-week long courses, the program would not be considered to be offered in modules for purposes of determining the applicability of the R2T4 requirements to that student’s withdrawal. [Guidance issued 07/20/2011; revised 08/20/2021]

MOD-Q2: Section 668.22(a)(2)(ii)(A)(1) provides that an institution is not required to treat a student who ceases attendance in a module-based program as a withdrawal if the institution obtains written confirmation from the student at the time that would have been a withdrawal of the date that he or she will attend a module that begins later in the same payment period or period of enrollment. What does "at the time that would have been a withdrawal" mean? Do we have to require the student to write the statement at the time they actually withdraw, or, if we run reports on a weekly basis to identify these students, can we request the student’s written confirmation of future attendance at that time?

MOD-A2: "At the time that would have been a withdrawal" means close to the date that the student actually ceased attendance and before the time when the institution was required to return Title IV funds, offer any post-withdrawal disbursement of loan funds, or take any other action under the R2T4 requirements. Without confirmation of future attendance, the institution must assume a student who has ceased attendance is a withdrawal and begin the R2T4 process. An institution is expected to begin the R2T4 process immediately upon its determination that a student has withdrawn in order to perform required actions in a timely manner, and may not delay the R2T4 process in case a student might return. Of course, because the notice must confirm attendance in a module that begins later in the same payment period or period of enrollment, the notice must always be obtained prior to the beginning of the module in which the student is confirming attendance. [Guidance issued 07/20/2011]

MOD-Q3: Does an online confirmation of future attendance from the student constitute written confirmation from the student that he or she will attend a module that begins later in the same payment period or period of enrollment?

MOD-A3: Yes, provided that the confirmation is a timely positive confirmation of future attendance. Thus, an institution must ensure that the online confirmation requires the student to reaffirm attendance in a module that begins later in the period if that attendance is the basis for the future attendance. For example, consider a student who is scheduled to attend two courses in the first of three modules in a period of enrollment and one course in the third module. The student uses the institution’s online process for dropping/adding courses to withdraw from both courses in the first module, but does not withdraw from the course in the third module. The institution may not assume that the student will be returning for the course in the third module for purposes of demonstrating confirmation of future attendance. Rather, the process must require the student to reaffirm his or her intent to attend the course in the third module in order to count as confirmation of future attendance for Title IV, HEA program purposes. Of course, if at the time of the withdrawal, the student enrolled in a course in a later module in the same payment period or period of enrollment (that the student was not previously scheduled to attend), the newly added course would count as positive confirmation of future attendance for Title IV, HEA program purposes. [Guidance issued 7/20/2011]

MOD-Q4: May an institution wait to perform a R2T4 calculation to see if a student who has withdrawn and has not provided written confirmation of future attendance will return later in the payment period or period of enrollment?

MOD-A4: No. An institution is required to "undo" the R2T4 calculation if a student who has withdrawn returns to the institution (1) within the same payment period or period of enrollment for a term-based credit hour program offered in modules; or (2) within 180 calendar days for a clock-hour or non-term credit hour program (§668.22(a)(2)(iii)). An institution is expected to begin the R2T4 process immediately upon its determination that a student has withdrawn in order to perform required actions in a timely manner. For example, an institution must always return any unearned Title IV funds it is responsible for returning as soon as possible, but no later than 45 days after the date of the institution determination that the student withdrew (§668.22(j)(1)); disburse directly to a student any amount of a post-withdrawal disbursement of grant funds due as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew (§668.22(a)(6)(ii)(B)(1)); and offer any post-withdrawal disbursement of loan funds within 30 days of the date of the institution’s determination that the student withdrew (§668.22(a)(6)(iii)(A)). Thus, an institution may not delay the R2T4 process in case a student might return. However, if a withdrawn student returns to the institution within the same payment period or period of enrollment for a term-based program offered in modules, or within 180 calendar days for a clock-hour or non-term credit hour program, and before the R2T4 process is begun or complete, the institution is not required to begin or complete the process. [Guidance issued 07/20/2011]

MOD-Q5: Under the regulations effective July 1, 2021 (unless early-implemented), section 668.22 (a)(2)(i)(C) provides that for a student in a standard or nonstandard-term program, excluding a subscription-based program, the student is considered withdrawn if not scheduled to begin another course within a payment period or period of enrollment for more than 45 calendar days after the end of the module the student ceased attending, unless the student is on approved leave of absence. Section 668.22 (a)(2)(i)(D) provides that a student in a non-term program or a subscription-based program is considered withdrawn if the student is unable to resume attendance within a payment period or period of enrollment for more than 60 calendar days after ceasing attendance, unless the student is on an approved leave of absence. If a student is a withdrawal under §668.22 (a)(2)(i)(C) or 668.22 (a)(2)(i)(D) because the student, who has completed a module or course in the payment period or period of enrollment, but does not meet any R2T4 withdrawal exemption and is not scheduled to attend another course in the payment period or period of enrollment in the required timeframe, what is the student’s withdrawal date?

MOD-A5: For an institution that is required to take attendance, a student’s withdrawal date is always the last date of academic attendance as determined by the institution from its attendance records (§668.22 (b)(1)). For an institution that is not required to take attendance, the withdrawal date is determined in accordance with the requirements of §668.22 (c). [Guidance issued 07/20/2011; revised 08/20/2021]

MOD-Q6: For regulations effective July 1, 2021 (unless early implemented) may an institution have a more onerous policy for a standard or nonstandard term program that requires the student to resume attendance in a later module within the payment period or period of enrollment in less than 45 days; for example, no more than 30 days after the end date of the module that the student completed or ceased attending?

MOD-A6: If an institution has a policy to administratively withdraw a student who does not begin attendance in another course within a period of time that is less than the 45-day period described in §668.22 (a)(2)(i)(C), the student would be considered a withdrawal for Title IV, HEA program purposes and the institution must determine the student’s withdrawal date in accordance with the requirements for administrative withdrawals. For an institution that is required to take attendance, a student’s withdrawal date is always the last date of academic attendance as determined by the institution from its attendance records (§668.22 (b)(1)). At an institution that is not required to take attendance, an administrative withdrawal is considered to be a withdrawal without student notification due to circumstances beyond the student’s control, and the withdrawal date is the date that the institution determines is related to that circumstance (§668.22 (c)(1)(iv)). The withdrawal date should be no later than the starting point of nonattendance that causes the institution to administratively withdraw the student. Thus, the last possible date of withdrawal for a student that is administratively withdrawn due to a period of nonattendance for a specified period is the beginning of the period of nonattendance that triggered the administrative withdrawal. [Guidance issued 07/20/2011]

MOD-Q7: If a student who withdrew from a term-based credit hour program offered in modules (excluding subscription-based programs) without providing written confirmation of future attendance later returns during the payment period or period of enrollment, thus requiring the institution to “undo” the R2T4 calculation in accordance with §668.22 (a)(2)(iii)(A), does the institution restore Title IV, HEA program funds to the amounts the student was originally scheduled to receive, or adjust those amounts to take into consideration periods the student was originally scheduled to attend, but did not attend?

MOD-A7: If a student withdraws from a term-based program offered in modules (excluding subscription-based programs), triggering a R2T4 calculation, and the student reenters the same program during the payment period or period of enrollment, the institution must restore the student’s original Title IV, HEA program funds award to the original amounts, with no adjustments required for partial attendance of a module. However, if a student did not attend an entire module he or she was originally scheduled to attend during the time he or she was away from the institution, the institution must adjust the student’s original Title IV, HEA program fund amounts to take into account that the student never began the courses in that module. [Guidance issued 07/20/2011]

MOD-Q8: If a student ceases attendance between modules—that is, the student completes one or more modules, but does not begin the next module he or she is scheduled to attend—is the student considered a withdrawal for Title IV, HEA program purposes?

MOD-A8: When determining whether a student enrolled in modules is a withdrawal for Title IV, HEA program purposes, an institution should consider:

1. Did the student cease to attend, or fail to begin attendance in a scheduled course that was included in the institution’s calculation of the student’s Title IV awards for the payment period or period of enrollment?

* If yes, go to question 2
* If no, the student is not a withdrawal

2. When the student ceased to attend or failed to begin attendance in a scheduled course, was the student attending other courses in the period?

* If yes, the student is not a withdrawal, but Pell recalculations may apply
* If no, go to question 3

3. When the student ceased to attend or failed to begin attendance in a scheduled course, did the student complete all the requirements for graduation?

* If yes, the student is not a withdrawal, but Pell recalculations may apply
* If no, go to question 4

4. When the student ceased to attend or failed to begin attendance in a scheduled course, did the student successfully complete:
* a module or combination of modules that contain 49 percent or more of the number of days of the payment period (excluding scheduled breaks of 5 consecutive days or more and all days between modules); OR
*coursework equal to or greater than the coursework required for the institution’s definition of a half-time student for the payment period?

* If yes to either question, student not a withdrawal, but Pell recalculations may apply
* If no, go to question 5

5. Did the student confirm attendance in a later point in the payment/enrollment period (a module that begins no later than 45 days after the date that the student withdrew for standard or nonstandard programs; or a date that is no later than 60 days from the date the student ceased attendance for non-term or subscription-based programs, as applicable)?

* If yes, the student is not a withdrawal, but Pell recalculations may apply
* If no, the student is a withdrawal

[Guidance issued 07/20/2011; revised 08/20/2021]

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: Archived

MOD-Q10: When performing an R2T4 calculation, are the days between modules included in the total number of calendar days in the period?

MOD-A10: The total number of calendar days in the payment period or period of enrollment includes all days in the payment period or period of enrollment, excluding days in which the student was on an approved leave of absence, and 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. So, breaks between modules that the student is scheduled to attend of at least five consecutive days are excluded from the total number of calendar days in the period when calculating the percentage of the period completed by the student. These breaks would be excluded both in the numerator and the denominator of the R2T4 calculation (§668.22(f)(2)(ii)(B)).

Please note this only applies to the process for determining the denominator for the R2T4 calculation. This is not the process for determining whether a student successfully completed at least 49 percent of the payment period for purposes of determining whether the student qualifies for an exemption from the R2T4 requirements (see question WI-Q4 below). [Guidance issued 07/20/2011; revised 08/20/2021]

MOD-Q11: Section 668.22(c)(1)(iii) provides that the withdrawal date for a student who withdraws from an institution that is not required to take attendance when the student does not provide official notification to the institution of his or her withdrawal (i.e., unofficially withdraws), is the midpoint of the payment period or period of enrollment. If a student unofficially withdraws from a program offered in modules at an institution that is not required to take attendance, how is the student’s withdrawal date (the midpoint of the period) determined?

MOD-A11: The midpoint of the payment period or period of enrollment would be the 50 percent point of the total number of calendar days in the payment period or period of enrollment. The total number of calendar days in the payment period or period of enrollment includes all days in the payment period or period of enrollment, excluding days in which the student was on an approved leave of absence, and 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 (§668.22(f)(2)). Consider a student who, after completing the first module (and does not qualify for a withdrawal exemption), withdraws on day 20 of the second module of a period comprising two eight-week modules with a four-day break in between. Because there are no scheduled breaks of at least five consecutive days during or between the modules, the total number of calendar days in the period would be the total number of days in each module (8 weeks x 7 days=56 days in each module; 56 days x 2 modules=112 days in the modules) plus the 4 days in between the modules (112 days in the modules + 4 days between modules) for a total of 116 calendar days in the period.) Therefore, the midpoint and, thus, the withdrawal date would be day 58.

Note that there may be situations where the withdrawal date determined using this method occurs slightly before or after the 50 percent point in the term. For example, the midpoint of a term that includes 117 calendar days would be the 59th day of the term because the institution, using normal rounding rules, would round the result of the calculation (58.5) to 59. In such cases, an institution must always treat the student as having earned exactly 50 percent of their Title IV funds for the period even if the calculation based on the withdrawal date at the midpoint would otherwise result in a different percentage (for example, 59 divided by 117 equals 50.4 percent).
[Guidance issued 07/20/2011; revised 08/20/2021]

MOD-Q12: The preamble to the final regulations effective July 1, 2011 states, “If the student has not begun attendance in enough courses to establish a half-time enrollment status, the institution may not make a first disbursement of a Direct Loan to a student (34 CFR 685.303(b)(2)(i))” (75 FR 66895 (October 29, 2010)). Does this mean that an institution must delay the first disbursement of Direct Loan funds until the student has begun attendance in enough hours to qualify as a half-time student?

MOD-A12: No, an institution is not required to delay the first disbursement of a Direct Loan until the student has begun attendance in enough classes to qualify as a half-time student. The statement in the preamble refers to a post-withdrawal disbursement of Title IV, HEA program funds—i.e., a disbursement of Title IV, HEA program funds made after the student withdraws that were earned but not received by the student while still attending the institution—to a student who is withdrawing from a program offered in modules, where the student has not begun attendance in all the courses in all the modules the student was originally scheduled to attend. Title IV, HEA program funds are disbursed to a student on the presumption that he or she will attend the hours for which aid has been awarded. Therefore, an institution is not required to delay the disbursement of Title IV, HEA program funds until a student has attended enough hours to qualify for the enrollment status for which the funds were awarded. However, if the student has withdrawn and has not begun attendance in enough courses to establish a half-time enrollment status, the presumption is no longer valid. Thus, the institution may not make a first disbursement of a Direct Loan (i.e., the first disbursement of a Direct Loan in a loan period) to a student. Section 668.164(g)(3)(iii), which permits an institution to make a late disbursement of a Direct Loan for costs incurred to a student who did not withdraw, but ceased to be enrolled as at least a half-time student, does not apply because the student never really was a half-time student. Take, for example, a credit hour program where each semester comprises three modules of five weeks each. If a student enrolls in one three-credit course in the first module, and one three-credit course in the second module, the student will not begin attendance in six credit hours, the institution’s minimum half-time enrollment status, until starting the course in the second module. The institution is not required to, nor should it, delay the disbursement of the student’s Direct Loan program funds until the student begins the course in the second module. However, if the student withdraws during the first module and the institution has not made the first disbursement of a Direct Loan to the student prior to the withdrawal, the institution may not make that first disbursement of the Direct Loan to the student at this point. [Guidance issued 07/20/2011; revised 08/20/2021]

MOD-Q13: The preamble to the final regulations effective July 1, 2011 states, "If the student has not begun attendance in enough courses to establish a half-time enrollment status, the institution may not make a first disbursement of a Direct Loan to a student (34 CFR 685.303(b)(2)(i)), or a second disbursement of Pell Grant funds, although the funds are included as aid that could have been disbursed in the R2T4 calculation." (75 FR 66895 (October 29, 2010).) Why is an institution prohibited from making a second disbursement of Pell Grant funds?

MOD-A13: The preamble to the July 1, 2011 regulations is incorrect. An institution would not be prohibited from making a second disbursement of Pell Grant funds if the R2T4 calculation resulted in a post-withdrawal disbursement of Pell Grant funds. We published a correction to the preamble language in the Federal Register on April 13, 2011 (76 FR 20534). [Guidance issued 07/20/2011; revised 08/20/2021]

MOD-Example— Archived

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: Archived

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 R2T4 purposes?

MOD-A15: Archived

MOD-Q16: Because of the requirements for retaking coursework, students are sometimes completing or repeating coursework for which they may not receive Title IV, HEA program funds. If a student withdraws from all other courses in the payment period or period of enrollment, as applicable, except for the non-Title IV eligible course(s) they are completing or repeating, are they a withdrawal for Title IV purposes? How does this apply to programs offered in modules?

MOD-A16: If a student withdraws from all Title IV eligible courses in the payment period or period of enrollment, and continues to attend only the course(s) that he or she is completing or repeating for which he or she may not receive Title IV aid during that period, the student is a withdrawal for Title IV purposes.

This is because a student is considered to be attending a Title IV eligible program only if they are attending one or more courses in that program for which the student is receiving Title IV, HEA program funds. Therefore, a student who ceased attendance in all of the Title IV eligible courses is considered to be no longer attending a Title IV eligible program and is a withdrawal for Title IV purposes, regardless of any continued attendance in courses for which the student may not receive Title IV, HEA program funds during that period.

For example, a student enrolls in four courses in the spring semester, three for the first time and one for the third time, having received Title IV aid and earning a grade of "D" for the repeated course the two previous times. Because an institution may pay a student only one time for retaking previously passed coursework, the repeated course would not be counted towards the student’s enrollment status and would not be eligible for Title IV aid. If the student then ceases attendance in the three courses he is taking for the first time, the student is a withdrawal for Title IV purposes, even though the student remains enrolled in the course he is repeating, because he ceased attendance in the Title IV eligible part of the program scheduled for that period.

Likewise, if a student who received an incomplete in a course in the prior term is completing the coursework in the subsequent term to erase the incomplete from the prior term, the student is not eligible for Title IV, HEA program funds for completion of the coursework. If the student withdraws from all the Title IV eligible coursework in which he or she is enrolled, but remains in attendance in only the coursework that needs to be completed from the previous term, the student is a withdrawal for Title IV purposes. Of course, if the student is retaking the entire course for credit in the subsequent term, the hours in the course count toward the student’s enrollment status and the student may receive Title IV, HEA program funds for retaking a failed course, or retaking a previously passed course one time.

The principle is the same for programs offered in modules. For example, a student is scheduled to attend one course in each of five modules during a semester. The student receives an incomplete in course number two in the second module and, because the student may not progress to course number three until course number two is completed, the student completes the remaining portion of course number two in the third module. While the student completes the incomplete portion of course number two in the third module, he or she is not be considered to be enrolled in the course for Title IV purposes, so attendance of just that course does not count as attendance for purposes of the R2T4 requirements. Therefore, in accordance with the requirements for the treatment of students in program offered in modules, the institution would need to obtain written confirmation of future attendance in a Title IV eligible course later in the semester at the time that would have been a withdrawal in accordance with §668.22(a)(2)(ii), or put the student on an approved leave of absence for the student not to be considered a withdrawal for Title IV purposes. Absent written confirmation of future attendance or being placed on an approved leave of absence, a Return to Title IV Funds calculation would be required (absent withdrawal exemptions or the student completing more than 60 percent of the period before withdrawing). However, if the student subsequently returns to a Title IV eligible course later in the period, the student’s R2T4 calculation would be undone in accordance with §668.22(a)(2)(iii). [Guidance issued 5/7/2012]

MOD-Q17: If a student who withdrew from a non-term credit hour program failed hours in the payment period, must the payment period be extended by the number of days necessary for successful completion of those hours?

MOD-A17: The total number of calendar days in the period must reflect the actual days the student would have had to attend to successfully complete all the hours the student was originally scheduled to complete in the period.

Section 668.22(f)(2) provides that the total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. Dear Colleague Letter GEN-04-03 (November 2004) provides that, for non-term credit hour programs, if the student has not successfully completed any courses in the payment period, the payment period must be extended to reflect the number of days in the failed courses that the student did not successfully complete. Section 668.4(c) defines how payment periods are determined for non-term credit hour programs. Completion of a payment period occurs when a student successfully completes the hours and weeks of instructional time in the period. Section 668.4(h) provides that a student successfully completes credit hours if the institution considers the student to have passed the coursework associated with those hours. If a student has not passed all the coursework associated with the hours in the payment period (in addition to completing the weeks of instructional time, unless the graduation withdrawal exemption applies), the student has not completed the payment period. So, any additional days beyond the original end date of the payment period that it would have taken for a student to complete the credits associated with any courses that ended prior to the student’s withdrawal that the student did not pass must be added to the total number of calendar days in the payment period when performing the R2T4 calculation.

If more than one course must be added for successful completion of the hours in the payment period and those courses could have been taken concurrently by the student had he or she remained enrolled, then the payment period would be extended by the days necessary to take the courses concurrently. However, if the only way the student could have taken the courses was consecutively, then the added days must reflect the days it would have taken to complete the courses consecutively. If prior to a student’s withdrawal, the student has added a course or courses to complete within the original payment period hours previously failed, the payment period would reflect the original end date. [Guidance issued 9/14/2012]

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]

MOD-Q19: Our institution has three summer periods in which students can enroll in coursework and those sessions are combined into a single summer term for the purposes of awarding Title IV funds. Is our summer term considered to be offered in modules?

MOD-A19: Yes. If an institution combines multiple summer sessions into a single term for Title IV purposes, and none of those sessions span the entire term, each of the summer sessions is considered a module and a student enrolling in any one of those session is treated as being enrolled in a program offered in modules for that term. [Guidance issued 08/20/2021]

Institutions that are Required to Take Attendance (TA)

TA-Q1: Guidance disseminated by the Department in Dear Colleague letter GEN 04-03 (February 2004) and revised in Dear Colleague letter GEN 04-12 (November 2004) provides that, for an institution that is required to take attendance, except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records. Does this 14-day rule for determining a withdrawal apply to all institutions that fall under the definition of an institution that is required to take attendance (i.e., those required to take attendance by an outside entity, those that have an institutional requirement to take attendance, and those that can only meet an externally or internally imposed requirement by taking attendance or a comparable process)? How does the 14-day rule apply when a student is not treated as a withdrawal from a program offered in modules because he or she has confirmed attendance in a module that begins later in the payment period or period of enrollment?

TA-A1: The 14-day rule applies to all institutions that are required to take attendance. Institutions that are required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdraws. The 14-day rule provides that, for an institution that is required to take attendance, except in unusual instances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records, except that we are modifying the 14-day rule from the guidance provided in Dear Colleague letter GEN 04-03 (February 2004) and revised in Dear Colleague letter GEN 04-12 (November 2004) to address the situation where a student is not treated as a withdrawal from a program offered in modules because he or she has confirmed attendance in a module that begins later in the payment period or period of enrollment. When in accordance with §668.22(a)(2)(ii)(A) or (B) a student is not treated as a withdrawal from a program offered in modules at an institution that is required to take attendance because the student has confirmed attendance in a module that begins later in the payment period or period of enrollment, no action is required by the institution unless the student does not return as scheduled. If the student does not return as scheduled, the student is treated as a withdrawal (see §668.22(a)(2)(ii)(C)(1)), and the date of the institution’s determination that the student withdrew should be no later than 14 days after the date that the student was scheduled to resume attendance. For example, a student enrolls at an institution that is required to take attendance for one course in each of three modules. The student completes the first module, but ceases attending the second module on October 4, prior to its completion. The student provides written confirmation that he will attend the third module, scheduled to begin October 24, but does not return. The institution must complete a R2T4 calculation using October 4—the student’s last date of academic attendance as determined by the institution from its attendance records—as the withdrawal date, and October 24 as the date of the institution’s determination that the student withdrew.

In accordance with the previous guidance, if a student provides notification to the institution of his or her withdrawal prior to the date that the institution normally would determine that the student withdrew, the date of determination is the date of the student's notification. The institution is NOT required to administratively withdraw a student who has been absent for 14 days. However, after 14 days, it is expected to have determined whether the student intends to return to classes or to withdraw. If the student is eventually determined to be a withdrawal, the end of the 14-day period begins the timeframe for completing a R2T4 calculation. If an institution has a policy that states the maximum number of excused absences that can occur after which a student will be administratively withdrawn, it may delay contacting the student until that date. However if the student eventually is determined to be withdrawn, the date of determination of the student’s withdrawal remains 14 days from the student’s last day of attendance. If the number of days in the institution’s policy is less than 14 days, then the date of the institution’s determination that the student withdrew is the date the institution’s policy indicates that the student will be administratively withdrawn. An institution must return the amount of Title IV funds for which it is responsible as soon as possible, but no later than 45 days after it determines or should have determined that the student withdrew. In addition, if a student is due a post-withdrawal disbursement, then the date of the institution’s determination must allow for the institution to meet the 30-day post-withdrawal disbursement notification requirement. This requirement does not affect a student’s withdrawal date. At an institution that is required to take attendance, a student’s withdrawal date is always the last date of attendance as determined by the institution from its attendance records. [Guidance issued 7/20/2011]

For additional information on the date of the institution’s determination that the student withdrew, see Volume 5—Overawards, Overpayments, and Withdrawal Calculations, Chapter 2—Withdrawals and the Return of Title IV Funds, of the Federal Student Aid Handbook.

TA-Q2: If an institution monitors whether its online students log into classes, is this an institution that is required to take attendance?

TA-A2: No. The monitoring of whether online students log into classes does not by itself result in an institution being an institution that is required to take attendance for Title IV, HEA program purposes because monitoring logins alone is not monitoring academic engagement (as defined under 34 CFR 600.2). However, an institution that collects and maintains information about students’ online activities for the purpose of tracking academic engagement is considered to be an institution that is required to take attendance if that tracking:

1) Involves monitoring student attendance in a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students; or

2) Is used to administratively withdraw students or to enforce an institutional attendance policy.

[Guidance issued 7/20/2011; revised 08/20/2021]

TA-Q3: If a student officially withdraws after the end of a limited period of required attendance taking, does the institution have to demonstrate that the student was in attendance after the attendance-taking period in order to determine the student’s withdrawal date under the requirements for an institution that is not required to take attendance?

TA-A3: Yes. Unless an institution that is required to take attendance for a limited period can demonstrate that a student who was not in attendance at the end of the limited period attended after that period, the student’s withdrawal date is determined according to the requirements for an institution that is required to take attendance (75 FR 66901 (October 29, 2010)). That is, the student’s withdrawal date is the last date of academic attendance during the period of attendance taking, as determined by the institution from its attendance records. Take, for example, a student who is not in attendance in his or her classes on the last day of a two-week period of required attendance taking. The student begins the institution’s withdrawal process two weeks after the end of the two-week period of required attendance taking. The institution must demonstrate that the student was in attendance after the two-week attendance-taking period in order to use the date the student begins the institution’s official withdrawal process as the withdrawal date. If it cannot, the student’s withdrawal date is the last date of academic attendance during the period of attendance taking, as determined by the institution from its attendance records. [Guidance issued 7/20/2011]

TA-Q4: If an institution requires its faculty to provide a last date of attendance for students who receive all “F” grades to determine whether a student with failing grades has unofficially withdrawn, is this an institution that is required to take attendance?

TA-A4: No. A requirement that faculty provide a last date of attendance for students who receive all “F” grades to determine whether a student with failing grades has unofficially withdrawn does not make an institution one that is required to take attendance for Title IV, HEA program purposes. Only if the institution requires its faculty to collect or record information about whether a student was in attendance is it considered to be one that is required to take attendance. For additional information on determining whether a student who failed to receive a passing grade is a withdrawal, see Volume 5—Overawards, Overpayments, and Withdrawal Calculations, Chapter 1—Withdrawals and the Return of Title IV Funds, of the Federal Student Aid Handbook. [Guidance issued 7/20/2011; revised 08/20/2021]

TA-Q5: If an institution requires its faculty to take attendance for some courses in a program, but not others (for example, all core courses, but not elective courses), is this an institution that is required to take attendance?

TA-A5: An institution is only required to take attendance if attendance taking is required in all classes in the program for a period of time. If, for example, an institution requires that attendance be taken in all core courses, but not elective courses, and the core and elective courses are always taken together throughout a payment period, then the institution would not be classified as being required to take attendance for that program because attendance taking is not required for all courses for any period of time. However, if the core courses in the program are taken together in isolation—for example, over the first five weeks of a payment period—then this would be a program for which the institution is required to take attendance for those first five weeks because, for that period of time, attendance is required in all courses. [Guidance issued 7/20/2011]

TA-Q6: Please confirm that an institution is not an institution that is required to take attendance if it has a census that reviews which students academically attended during a defined preceding period--e.g., determines who attended during the first two weeks of a course--rather than being limited to students’ academic attendance on just one date.

TA-A6: Section 668.22 (b)(3)(iv) provides that an institution is not an institution that is required to take attendance for Title IV, HEA program purposes if the institution takes attendance on only one specified day to meet a census reporting requirement. So, if the institution is taking attendance on just the 14th day, it is not an institution that is required to take attendance for Title IV, HEA program purposes. Also, if the institution is taking attendance to determine whether each student attended at least once during the period, but is not continuing to monitor attendance for a student subsequent to the one day of attendance, it is not an institution that is required to take attendance for Title IV, HEA program purposes. If, however, the institution is taking attendance throughout the two weeks to determine when students are and are not present, then in accordance with §668.22(b)(3)(iii), the institution is taking attendance for a limited period and the institution is one that is required to take attendance for Title IV, HEA program purposes for that limited period. [Guidance issued 7/20/2011]

TA-Q7: For a program that is offered in modules, may the institution require that attendance be taken on only one specified day for each module (i.e., have one census date per module) without the institution being considered an institution that is required to take attendance for Title IV, HEA program purposes.

TA-A7: Yes. [Guidance issued 7/20/2011]

TA-Q8: If faculty at an institution are required to take attendance and some faculty do not comply with the requirement, how should the institution determine a withdrawal date for a student who withdraws?

TA-A8: If attendance taking is required, either by an outside entity, the institution itself, or the institution or the outside entity has a requirement that can only be met by taking attendance or a comparable process, the institution is one that is required to take attendance for Title IV, HEA program purposes and the student’s withdrawal date is always the last date of academic attendance as determined by the institution from its attendance records. The institution is responsible for ensuring that it is in compliance with the requirement to take attendance. If some faculty does not comply with the required attendance taking, a student’s withdrawal date will be the last date of academic attendance from the attendance records taken by the faculty that did take attendance. If no records of a student’s academic attendance exist, the student is considered not to have begun attendance for Title IV, HEA program purposes and, therefore, never established eligibility for the Title IV, HEA program funds. The Title IV, HEA program funds must be handled by the institution in accordance with the requirements for the treatment of Title IV grant and loan funds if the recipient does not begin attendance at the institution in §668.21, rather than the R2T4 requirements in §668.22. [Guidance issued 7/20/2011]

TA-Q9: For institutions required to take attendance, if a student in a non-term program does not provide written confirmation to resume attending within 60 calendar days after the student ceased attendance, does the date of the institution’s determination need to be no later than 14 days after the student’s last date of attendance?

TA-A9: Yes, except in unusual circumstances, the date of the institution’s determination that the student withdrew should be no later than 14 days after the student’s last date of attendance as determined by the institution from its attendance records, including in cases where a student fails to provide written confirmation of his/her intent to return to a module later in the same payment period or period of enrollment. [Guidance issued 08/20/2021]

TA-Q10: One of our students completed an online orientation prior to the start of a term, but we have no record of academic engagement after the term started. Can we use documentation of the student’s participation in the orientation as a record of attendance?

TA-A10: Only active participation by a student in an instructional activity related to the student's course of study that meets the definition of “academic engagement” in 34 CFR 600.2 and takes place during a payment period or period of enrollment qualifies as attendance in an academically related activity. If a period of orientation takes place prior to the start of a course, it would not qualify as attendance in an academically related activity.

Additionally, an orientation may or may not be considered academic engagement depending on the types of activities that are involved in the orientation. Neither the definition of academic engagement nor the Department’s guidance provide an exhaustive list of the types of activities that could be considered academic engagement. Institutions should make clear what will and will not be considered academic engagement in their policies and procedures and apply those policies and procedures consistently to all students. [Guidance issued 08/20/2021]

Enrollment Reporting (ER)

ER-Q1: If a student withdraws during a payment period but is not subject to the R2T4 requirements due to a withdrawal exemption, is the student reported to the National Student Loan Data System (NSLDS) as a withdrawal? If so, what should the institution use as the effective date of the withdrawal?

ER-A1: There are occasions when a student is considered withdrawn for enrollment reporting purposes but no R2T4 calculation has to be performed (such as when a student completes a term but does not return for a subsequent term). If the student is not treated as a withdrawal and there is no R2T4 calculation, then the institution does not have to use the R2T4 process to determine the effective date of the withdrawal for NSLDS enrollment reporting purposes.

When a student completes a term and does not return for the next term, leaving the course of study uncompleted, the effective date for the “W” (withdrawn) status is the final day of the term in which the student was last enrolled. This guidance remains in effect under the Distance Education and Innovation regulations effective July 1, 2021, which treat students as having completed a term when they meet the conditions for an exemption from treatment as a withdrawal.

Therefore, when a student is treated as having completed a term (e.g., because the student successfully completes a module or modules comprising at least 49 percent of the term), but has not graduated, the institution must report the student as withdrawn as of the final day of the payment period in which the student was last enrolled. Conversely, if the student is treated as a withdrawal and the R2T4 requirements apply, the institution must report the student as withdrawn with an effective date as determined under 34 CFR 668.22.

If a student meets the conditions for a withdrawal exemption for graduating or completing all requirements for graduation, the institution may continue to follow the current graduation requirements outlined in the NSLDS Enrollment Reporting Guide, which indicate that “the effective date for a completion/graduation status (“G”) is the date that the institution assigns to the completion/graduation.”

Therefore, when a student graduates during a term upon completion of a module with an end date that occurs prior to the end date of the term, the institution should use the effective date that it assigns for graduation. This effective date could be the end of the module, the date that the credential was conferred, the term end date, or another date consistent with the institution’s policies for assigning a graduation date. [Guidance issued 08/20/2021]

Grades and Incompletes (GI)

GI-Q1: Our institution maintains a grading policy that distinguishes between students who completed a course, but who failed to achieve the course objectives (an “earned “F” grade”) and students who failed to complete the course (a “W” grade). The Department provides that a student is not considered withdrawn if the student receives an “earned F” (as explained in Dear Colleague Letter GEN-04-03) at the end of a module and is not scheduled to attend any subsequent modules during the term. Is an “earned F” in this context considered a passing grade that denotes successful completion of the module for withdrawal exemption purposes?

GI-A1: No. Successful completion means earning a passing grade under an institution’s overall academic grading policy. Courses in which a student received grades that are not passing, including earned or unearned “F” grades, an incomplete grade (“I”) or a withdrawal (“W”) grade, are not considered to have been successfully completed and cannot be used to determine if the student qualifies for a withdrawal exemption.

To qualify for a withdrawal exemption for successfully completing a module that comprises at least 49 percent of the days in a payment period (excluding scheduled breaks of five or more consecutive days and all days between modules), a student would need to earn a passing grade in at least one course offered in that module. Similarly, to be considered to have completed a combination of modules that comprises at least 49 percent of the days in the payment period (excluding scheduled breaks of five or more consecutive days and all days between modules), the student must have earned a passing grade in at least one course in each of the modules that were used to calculate whether the student met the conditions for the exemption. [Guidance issued 08/20/2021]

GI-Q2: Our institution’s general grading policy states that a “D” grade is considered passing. However, in one of our graduate programs, a course does not count toward completion of the student’s program unless the student earns a grade of “C” or better. If a student in this program earns a “D” grade, which is a passing grade per the institution’s general grading policy, but the specific graduate program requires a “C” grade for successful completion of a course, is the “D” grade considered successful completion for purposes of the withdrawal exemptions?

GI-A2: Yes. Successful completion for purposes of the withdrawal exemptions should be based on an institution’s general grading policy and not the individual program grading policies. Therefore, if an institution’s general institutional grading policy has established that a “D” grade is considered a passing grade, then receipt of a “D” grade for a course would be considered successful completion of that course for the purposes of determining whether a withdrawal exemption applies. In this specific example, the “D” grade would be considered successful completion for the purpose of determining if the student qualifies for a withdrawal exemption. [Guidance issued 08/20/2021]

GI-Q3: We have a student who received “earned F” grades in each course in each module for which the student enrolled. We know that the student does not qualify for one of the withdrawal exemptions because an “F” grade is not considered “successful completion” of a course. However, if we determine they completed the full semester, would we be required to treat the student as withdrawn and complete an R2T4 calculation?

GI-A3: A student who receives at least one “earned F” grade at the end of the last module that the student was scheduled to attend during the period is not considered withdrawn. As provided in Dear Colleague Letter GEN-04-03, an institution with a grading policy that distinguishes between an “earned F” and an “unearned F,” a student is not considered withdrawn if the student ceases attendance at the end of a module or class for which the student receives an “earned F” and is not scheduled to attend any other course or module during the period. [Guidance issued 08/20/2021]

GI-Q4: At the end of a term, a student has ceased attendance and does not meet any of the conditions for a withdrawal exemption, but received incomplete (“I”) grades for all the courses in which the student was enrolled during the term. Can we treat this student as having completed the payment period, or do we need to perform an R2T4 calculation?

GI-A4: In term-based programs, students who are unable to complete the requirements of an individual course are often assigned the grade of incomplete (“I”). Students are usually expected to complete the required work within a reasonable time to receive credit and a passing grade. However, an incomplete (“I”) grade does not constitute completion of a course, and a student who ceases attendance does not meet any of the conditions for a withdrawal exemption, and has not received an “earned F” or similar grade, must be considered withdrawn (unless the student is on an approved leave of absence, see below for more explanation).

In general, an institution must perform an R2T4 calculation for a student within the required timeframe unless it has evidence that the student completed the payment period or period of enrollment. An institution can document that a student has completed a payment period or period of enrollment if the student has received a passing grade in the last course or courses that the student was scheduled to attend for that period. However, if a student does not have passing grades and an institution has no other evidence that the student completed the period, the student must be treated as a withdrawal (unless the student is on an approved leave of absence). Thus, if the student received only incomplete (“I”) grades and is permitted to continue working on those courses after the end of the period, the institution cannot presume that the student will complete the courses, and must therefore perform the R2T4 calculation by the applicable deadline unless the student receives a passing grade or a grade denoting completion of the course, but not the course objectives (e.g., an “earned F”) in one of those courses prior to the R2T4 deadline.

Note: In a very limited number of circumstances, a student who is awarded the grade of incomplete (“I”) in all classes can be treated as a student on an approved LOA, but only if the institution grants the LOA in accordance with the criteria in 34 CFR 668.22(d). A term-based, credit-hour institution that wishes to explore the possibility of granting an LOA that meets the criteria specified in 34 CFR 668.22(d) should call its School Participation Division for guidance. [Guidance issued 08/20/2021]

Withdrawal Exemptions in Programs Offered in Modules (WI)

WI-Q1: Do the withdrawal exemption regulations apply to both undergraduate and graduate students and programs?

WI-A1: Yes. The exemptions apply to all students who withdraw, regardless of program level or graduate or undergraduate status. [Guidance issued 08/20/2021]

WI-Q2: A term is broken into four consecutive five-week modules, each of which constitutes 25 percent of the payment period. If a student successfully completes only the first and last modules, would the student be exempt from the R2T4 calculation even though the modules that the student completed did not occur consecutively?

WI-A2: In a program offered in modules, a student is not considered to have withdrawn if the student successfully completes a combination of modules that, when combined, include 49 percent or more of the number of days in the payment period, excluding scheduled breaks of five or more consecutive days and all days between modules. Which modules a student successfully completes, and in what order the modules are completed, does not impact an institution’s determination of whether the student qualifies for a withdrawal exemption. [Guidance issued 08/20/2021]

WI-Q3: How does an institution establish the denominator for the calculation to determine whether a student has successfully completed at least 49 percent of a payment period or period of enrollment? Does the institution use the same method for determining the denominator as the R2T4 calculation itself?

WI-A3: The method for determining the denominator for the withdrawal exemption differs from the method for determining the denominator for the R2T4 calculation itself.

To determine the denominator of the calculation for whether a student has successfully completed at least 49 percent of a payment period or period of enrollment, an institution performs three steps. The institution—

  1. Adds all the days between the start and end date of the regular term (or all the terms in the period of enrollment);
  2. Subtracts any scheduled breaks of five consecutive days or more that apply to all students who enroll in the term; and
  3. Subtracts all days between modules.

The number of days in the term for purposes of the withdrawal exemption will be the same for all students who enrolled in that term. It does not vary with an individual’s enrollment. Only the numerator of the withdrawal exemption calculation – the number of days in modules that the student successfully completed – may differ for each student.

For example, consider a term that is comprised of two modules, each of which is 48 days in length. There are no scheduled breaks of more than five consecutive days during the semester but there is a four-day break between the two modules. The institution begins by adding all the days between the start and end date of the regular term (100 days) and then subtracting the number of days between the modules in the term (four days). The total number of days in the denominator of the withdrawal exemption calculation for this term is therefore 96 days.

A student enrolls during this term in one three-credit 100-day course and one three-credit, 48-day course in the first module. There are no scheduled breaks of five or more consecutive days during the semester but there is a four-day break between modules. The student successfully completes the first module and subsequently completely withdraws from the 100-day course. The student qualifies for the withdrawal exemption because the student has successfully completed a module that includes days comprising 50 percent of the days in the term (48/96 = 50 percent).

This process is different from the process to determine the denominator in the R2T4 calculation itself. The denominator of the R2T4 calculation includes days between modules if there are fewer than five consecutive days between modules. The denominator of the R2T4 calculation also varies by student, and includes only the days in modules that the student attended or that were included in the institution’s determination of that student’s Title IV eligibility for the term. [Guidance issued 08/20/2021]

WI-Q4: When a student enrolls in an intersession that is connected to another term (e.g., the fall or spring term), the intersession is treated as a module that the student is scheduled to attend and may therefore be included in the denominator of the student’s R2T4 calculation for a withdrawn student if the student attends the intersession or if the intersession is included in the institution’s determination of the student’s Title IV eligibility. Are intersessions included in the denominator for the withdrawal exemption calculation in the same manner?

WI-A4: No. As explained in WI-A3, the denominator of the withdrawal exemption calculation is the same for all students who enroll in a given term. By definition, an intersession is attached to a term and is not part of the regular term. Therefore, the days in an intersession are always excluded from the denominator of the withdrawal exemption calculation. Similarly, any other days that occur outside the regular term dates (e.g., coursework that begins prior to the regular term dates, coursework taken during a consortium agreement, or coursework taken as part of a study-abroad program) are never included in the denominator of the withdrawal exemption calculation.

For example, consider an intersession that is 40 days in length and a regular Spring term to which it is attached that includes 80 days with no scheduled breaks. A student is scheduled to attend one full-term course during the regular Spring term and one course during the intersession. The student successfully completes the intersession course, but does not attend the full-term course that the student was scheduled to attend. This student is considered to be enrolled in a program offered in modules because the intersession and full-term courses are both considered modules in the student’s overall enrollment.

The denominator of the withdrawal exemption calculation includes the 80 days in the regular term and ignores the days in the intersession. Therefore, because the student successfully completed the intersession course, which included 40 days (50 percent of the number of days in the regular term), the student is treated as having completed a module comprising at least 49 percent of the days in the regular term. This student qualifies for a withdrawal exemption and no R2T4 calculation is required. [Guidance issued 08/20/2021]

WI-Q5: A student withdraws from a degree program in the middle of a payment period, but graduates from a shorter certificate program (unaffiliated with the program in which the student is enrolled as a regular student) at that time based on coursework that was completed at the time the student withdrew. The student did not graduate from the degree program, which was the program in which the student was enrolled as a regular student and was the basis of the student’s Title IV eligibility. Would the withdrawal exemption for graduation or completion of requirements for graduation apply to this student?

WI-A5: No. The regulations for the graduation withdrawal exemption were intended to apply only to graduation from the program in which the student was enrolled as a regular student and for which the student was receiving Title IV aid for the payment period in question. The exemption does not apply when a student graduates or receives a credential for another program. [Guidance issued 08/20/2021]

WI-Q6: An institution only offers classes that span the length of a payment period and a single module that begins at the start of the period and ends in the middle of the period. Is the institution permitted to exclude all days outside the module from the denominator of the withdrawal exemption calculation as days that are “between modules”?

WI-A6: No. Because the institution only offers one module during the payment period, there are no breaks “in between” modules to exclude. The denominator of the withdrawal exemption calculation would include all days in the normal term excluding any scheduled breaks of at least five consecutive days. [Guidance issued 08/20/2021]

WI-Q7: We have modules of various lengths and some overlap. We only have breaks between certain modules, but some breaks are not common to all modules. When counting days in the modules to determine if the student meets the conditions for a withdrawal exemption for successful completion of a module or modules that comprise at least 49 percent of the payment period, do we include all breaks or only breaks that are common to all modules during the payment period?

WI-A7: For purposes of performing the calculation to determine whether the student meets the conditions for a withdrawal exemption for successful completion of at least 49 percent of the payment period, a day is included in the numerator if that day was included in at least one module or full-term course that the student successfully completed and is not part of a break of at least five consecutive days during which no coursework was taking place. The process for determining the number of days in the denominator of this calculation is described in WI-A3. For either the numerator or denominator, if a day is included in multiple overlapping modules, the day is only counted once.

For example, if the payment period includes four modules and there is a three-day break between each module, then the institution would subtract nine total break days between modules from the total number of days in the payment period. However, if the four modules overlapped one another and there were not any breaks between modules, the institution would not subtract any break days between modules from the denominator of the withdrawal exemption calculation. [Guidance issued 08/20/2021]

WI-Q8: An institution offers both modules and courses that span the entire payment period. The full-term courses have a scheduled break of at least five consecutive days, but there is no scheduled break in the modules as there is in the full-term courses. Should we exclude the scheduled break in the full-term course from the denominator of the withdrawal exemption calculation?

WI-A8: No. If a scheduled break applies to some courses in the term, but not others, it is not excluded from the denominator of the withdrawal exemption calculation. However, when determining the numerator of the withdrawal exemption calculation, the institution must exclude scheduled breaks of at least five consecutive days in each module that the student successfully completed regardless of whether those scheduled breaks apply to other courses in the term.

Note that the process for establishing the denominator of the withdrawal exemption calculation differs from the treatment of scheduled breaks for purposes of the R2T4 calculation itself. Whether an institution excludes a scheduled break from an individual’s R2T4 calculation depends on whether there was a scheduled break of at least five consecutive days for that particular individual. [Guidance issued 08/20/2021]

Clock Hour Programs (CHP)

CHP-Q1: Our State permits students to graduate prior to completing all of the clock hours normally established in a program if the students can demonstrate that they have mastered all the skills in the program. One of our students has graduated from a 900-hour clock hour program before successfully completing all of the clock hours in the program that is established in our institution’s Eligibility and Certification Approval Report (ECAR). The student graduated having successfully completed only 750 clock hours. Given to the changes to the regulations effective July 1, 2021, is this student exempt from the R2T4 requirements?

CHP-A1: Yes. Although the student did not successfully complete all the clock hours in the program, they are not treated as a withdrawal and the institution is not required to perform an R2T4 calculation because the student graduated from the program.

However, allowing a student to graduate before successfully completing the hours in the program could still require the institution to return Title IV funds for the student. A student’s eligibility for Title IV aid in a clock-hour program is based, in part, on the overall number of clock hours in the student’s program of study. When an institution allows a student to graduate from a clock hour program without completing all of the established hours in the program, the institution has effectively shortened the program’s length – resulting in reduced Title IV eligibility – for the student. Therefore, if a student graduates from a clock hour program without successfully completing all of the established clock hours in the program, the institution must recalculate the student’s eligibility for all Title IV aid in the program and must perform a new proration of the student’s Pell Grants and Direct Loans as if the student had been enrolled in a program with fewer clock hours.

Then, if the institution had disbursed Title IV aid in an amount greater than the amount that it recalculates, the institution must return the difference between the recalculated amount of Title IV for which the student was eligible based on enrollment in the shorter program and the amount that was disbursed. The institution, not the student, is ultimately responsible for returning the Title IV aid in these situations.

For example, if the student in this situation had a zero EFC, the institution would have originally disbursed a full Pell Grant ($6,495 in the 2021-2022 award year) to the student based on the student’s enrollment in a 900-clock hour program. Assuming that the student qualified for Direct Loan funds, the institution would also have disbursed $3,500 in Subsidized Direct Loan funds to the student. However, when the institution allows the student to graduate with only 750 hours, it recalculates the student’s eligibility for both Pell Grant and Direct Loan funds as if the student had been enrolled in a 750-hour program. To do this, the institution prorates the student’s Pell Grant disbursements as if each disbursement were associated with a payment period of 375 hours, resulting in two disbursements of $2,706 (375/900 * 6495). Because the institution had originally disbursed $3,247 and $3,248 in Pell Grant funds for the first and second payment periods, respectively, the institution reduces the first disbursement by $541 and the second disbursement by $542. The institution then returns the total difference in Pell Grant eligibility, $1,083, to the Department. The institution also prorates the student’s Subsidized Direct Loan award based on a program length of 750 hours, resulting in a prorated Subsidized Direct Loan award of $2,917. Because the institution had originally disbursed $1,750 (gross) in Direct Loan funds for each payment period, the institution reduces the first disbursement by $291 and the second disbursement by $292. The institution then returns the total difference of $583 in Direct Loan funds to the Department.

Note that though proration of Pell Grant or Direct Loan awards normally involves consideration of the number of weeks of instruction in the program, when prorating a student’s awards in this situation the institution does not consider the number of weeks of instructional time completed by the student. This is because, as explained in CHP-A2, the Department expects that students will progress individually through clock hour programs and not all students will successfully complete all of the hours in a program at the same time.

Please note that this situation is a limited exception to the Department’s normal guidance that an institution is not required to return Direct Loan funds for a student if the student’s eligibility is reduced after the student has received all disbursements of the loan. The Department treats a situation when a student graduates before successfully completing the hours in a clock hour program as a situation where the student had graduated from a shorter program, and therefore was never eligible for the additional funds, including when the original disbursements were made. The Department’s normal guidance regarding recalculation of Direct Loan eligibility presumes that the student was eligible when the institution originally made the Direct Loan disbursements. [Guidance issued 08/20/2021]

CHP-Q2: If a student enrolled in a clock hour program successfully completes all of the clock hours in the final payment period, but does so before completing all of the instructional weeks scheduled in the payment period, would that also require re-proration?

CHP-A2: No. If a student successfully completes all clock hours in a program prior to the normal number of weeks elapsing, the student is not considered a withdrawn student and no proration of Title IV aid received has to occur.

Students progress individually through clock hour programs. and though an institution is required to calculate and report to the Department the number of weeks of instruction in a clock hour program, those weeks are an estimate of how long it normally takes the majority of students enrolled in that program to complete the program of study. Therefore, it is not uncommon for some students to complete a program somewhat earlier or later than the reported weeks. However, the number of clock hours that make up a program of study are the same for all students.

Of course, if a majority of students are completing the program in fewer weeks than the number that is reported to the Department on the institution’s Eligibility and Certification Approval Report (ECAR), the institution must review and adjust the number of weeks it normally takes the majority of their full-time students to complete the program of study. As a reminder, if a student successfully completes all of the hours in the program before completing a sufficient number of weeks of instruction to enter the final payment period, the student will not qualify for any Title IV disbursements for that final payment period. [Guidance issued 08/20/2021]

CHP-Q3: How should an institution treat hours of excused absences when a student is permitted to graduate before successfully completing all of the clock hours in a program?

CHP-A3: If an institution has an excused absence policy that meets the Department’s requirements under 34 CFR 668.4(e), clock hours associated with excused absences are considered successfully completed for Title IV purposes. If a student has successfully completed 100 percent of a program’s hours, factoring in any allowable excused absences, no re-proration of Title IV aid would be required since the student would be considered to have completed all of the clock hours in the program of study for Title IV purposes. [Guidance issued 08/20/2021]

CHP-Q4: In some situations, students will be permitted to graduate before successfully completing all of the clock hours in the program after the point at which the student was scheduled to complete at least 60 percent of the payment period or period of enrollment. In these situations, can the institution choose not to apply the R2T4 exemption and perform the R2T4 calculation instead? 

CHP-A4: No. The regulations at 34 CFR 668.22(a)(ii)(A)(1) specifically state that a student who completes all the requirements for graduation from his or her program before completing the days or hours in the period that he or she was scheduled to complete is not considered to have withdrawn. An institution may not apply the R2T4 requirements to a student who, under the regulations, is not considered to be a withdrawn student for Title IV purposes. Instead, the institution must recalculate the student’s eligibility for Title IV aid based on enrollment in a program that includes a smaller number of clock hours, as described in CHP-A1. [Guidance issued 08/20/2021]

Scheduled Days in a Payment Period for a Program Offered in Modules (SD)

SD-Q1: A student enrolls in two 30-day modules in a term, but does not enroll in any full-term courses. The student completes (but fails) the first module, then begins attendance in the second module, but subsequently withdraws before completing it. There is a four-day break between the modules during which the student was not enrolled in any classes. Is this scheduled break included in the calculation?

SD-A1: Yes. Because the student attended both modules, the days in both modules would be included in the total number of days in the payment period. For this student, there was also a short break of four days between the two modules when the student was not enrolled in any other courses. However, only scheduled breaks of at least five scheduled days or breaks between modules that consist of five or more consecutive days during which a student is not enrolled in other courses are excluded from the R2T4 calculation.

Therefore, because the number of consecutive days between modules for this student is fewer than five, those days would be included in the R2T4 calculation. The denominator of the calculation for this student would include 64 days. [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]

SCENARIO

An institution offers a program that uses 120-day standard terms with no scheduled breaks. The term includes four modules which are each 30 days long (Modules A, B, C, and D). Each module consists of one three-credit class, and the institution’s definition of full-time enrollment is 12 credits. None of the modules overlap and the institution does not use an R2T4 Freeze Date.

SD-Q3: A student who is eligible for only Direct Loan funds enrolls in Modules A, C, and D. The student completes Module A. While attending Module C, the student drops all classes in both Modules C and D on the same day. Which days are included in the enrollment period?

SD-A3: The institution must include the days in Modules A, C, and D in the R2T4 calculation because the institution does not use an R2T4 Freeze Date, the student was eligible for Direct Loan funds, and the student was enrolled in all three of those modules during the period. The denominator of the calculation would include 90 days. [Guidance issued 08/20/2021]

SD-Q4: A student who is eligible for only Pell Grant funds is enrolled in Modules A and B on the institution’s Pell Grant recalculation date, resulting in a half-time Pell Grant enrollment status for the period. The student completes Module A, but drops Module B before it begins while simultaneously registering for Modules C and D. The student subsequently completes (but fails) Module C and attends Module D, but withdraws halfway through that module. The student attended coursework comprising three-quarters-time enrollment, but the Pell Grant disbursement is based on a half-time enrollment status due to the student’s enrollment on the Pell Grant recalculation date. Which days are included in the R2T4 calculation?

SD-A4: The institution must include the days from Modules A, C, and D because the institution does not use an R2T4 Freeze Date, the student was eligible for only Pell Grant funds (and not Direct Loan or FSEOG) and the student attended those modules. The institution would not include the days in Module B because the student never attended Module B. The denominator of the R2T4 calculation would include 90 days.

Note that, for purposes of determining the days to include in the R2T4 calculation, the fact that the student was only considered to be enrolled half-time for Pell Grant purposes due to the student’s enrollment on the Pell Grant recalculation date is irrelevant. [Guidance issued 08/20/2021]

SD-Q5: A student who is eligible for both Pell Grant and Direct Loan funds enrolls in Modules A and B. The student attends Module A, but in the middle of that module, the student drops Module B. The student registers for Modules C and D at the same time Module B is dropped. The student then successfully completes Module A, but because that module includes less than 49 percent of the days in the payment period, the student does not qualify for the withdrawal exemption. The student does not ultimately attend either Module C or Module D, and is therefore considered withdrawn. Which modules are included in the R2T4 calculation?

SD-A5: The institution must include the days from Modules A, B, C, and D in the R2T4 calculation because the institution does not use an R2T4 Freeze Date, the student was eligible for Direct Loan funds (in addition to Pell Grant funds), and the student was enrolled in all four of those modules during the period. The denominator of the R2T4 calculation would include 120 days. [Guidance issued 08/20/2021]

R2T4 Calculation Freeze Date (RCFD)

RCFD-Q1: Is an R2T4 Freeze Date different from a Pell recalculation date?

RCFD-A1: Yes. An R2T4 Freeze Date is an optional (not required) policy that uses the student’s enrollment schedule at a fixed point to determine the number of days the student is scheduled to attend during the period for R2T4 purposes. A Pell recalculation date is an optional (not required) policy of recalculating an award if a student’s enrollment status changes within a term. These are two separate concepts, and though the two dates may be the same, they are used for different purposes. The R2T4 Freeze Date can coincide with other dates (e.g. census dates, Pell recalculation dates, etc.) or be a separate date. Similar to Pell recalculation dates, institutions may use multiple R2T4 Freeze Dates for multiple modules. [Guidance issued 08/20/2021]

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 institution’s R2T4 Freeze Date policy must be applied consistently to all students in the same program. [Guidance issued 08/20/2021]

RCFD-Q3: Can an attendance-taking institution use the R2T4 Freeze Date as a student’s withdrawal date or are we required to use the last day of attendance?

RCFD-A3: At an institution that is required to take attendance, a student’s withdrawal date is always the last date of attendance as determined by the institution from its attendance records. The R2T4 Freeze Date is never used as the basis for a withdrawal date; it is only used to determine the total number of days in the payment period or period of enrollment (i.e., the denominator of the R2T4 calculation). [Guidance issued 08/20/2021]

RCFD-Q4: Are there any restrictions on when an institution can set the R2T4 Freeze Date?

RCFD-A4: When establishing an R2T4 Freeze Date, an institution must ensure that the R2T4 Freeze Date for a given payment period or period of enrollment will not occur prior to the timeframe when most students enroll for classes for the period. An institution is not permitted to structure the timing of students’ enrollment such that students can only enroll in a single module when the R2T4 Freeze Date occurs but then enroll in other modules and receive more Title IV aid after the R2T4 Freeze Date.

If the Department determines that an institution has structured its enrollment and R2T4 Freeze Date for a period in this manner, we will require the denominator of all R2T4 calculations for that period to incorporate all changes to Title IV enrollment. [Guidance issued 08/20/2021]

RCFD-Q5: If an institution chooses to use an R2T4 Freeze Date, is it required to use an R2T4 Freeze Date for every payment period or period of an enrollment?

RCFD-A5: The R2T4 Freeze Date is optional. An institution is not required to implement a R2T4 Freeze Date for programs offered in modules. However, if an institution implements an R2T4 Freeze Date in one or all modules in a payment period or period of enrollment, the policy should be consistent across all payment periods or periods of enrollment in the program in those periods that contain modules. For example, if an entire program contains modules in each payment period, the institution cannot alternate between having an R2T4 Freeze Date in one period and not having an R2T4 Freeze Date in the subsequent period. [Guidance issued 08/20/2021]

RCFD-Q6: If an institution maintains multiple R2T4 Freeze Dates to coincide with multiple modules, is the R2T4 Freeze Date that applies to a student the one associated with the last class in which the student enrolls and attends?

RCFD-A6: Yes. Like multiple Pell recalculation dates, a student will only have one R2T4 Freeze Date apply to them within a payment period or period of enrollment. The institution will use the last R2T4 Freeze Date in the period that applies to a student. And, like Pell recalculation dates, an R2T4 Freeze Date applicable to a particular module is applicable only if the student actually starts attending that module. However, remember that if a student attends one day in a module, the days in that module must be included in the R2T4 calculation regardless of whether or not that course has been dropped by the student’s latest R2T4 Freeze Date. [Guidance issued 08/20/2021]

Institutional Charges (INST)

INST-Q1: On some occasions, even if a student attends a module and subsequently withdraws before completing more than a week, our institution will refund all tuition charges for that module. Does the tuition refund for the module affect whether the days in the module are included in the R2T4 calculation?

INST-A1: No. Whether an institution cancels or refunds tuition charges for a module does not impact whether the days in that module are included in the R2T4 calculation. The institution would still include the days in the module for which tuition charges were refunded in the R2T4 calculation. In this case, the days in the module would be included in the R2T4 calculation because the student attended at least one day in the module.

The R2T4 regulations do not prohibit an institution from developing its own tuition refund policy. However, the institution must comply with refund policies required by a state or other outside agencies. Although an institution, State, or accrediting agency refund policy will determine the charges a student will owe after withdrawing, those policies will not affect the amount of Title IV aid the student has earned under the R2T4 calculation. [Guidance issued 08/20/2021]

INST-Q2: For purposes of determining the amount of institutional charges to include in Step 5 of the R2T4 calculation, do we only include the charges for the modules that are included in the calculation? Our institution charges at the beginning of a payment period for all modules.

INST-A2: For purposes of determining the amount of institutional charges to use in the R2T4 calculation, an institution must always use the initial charges assessed the student for the entire payment period or period of enrollment. An institution only accounts for adjustments to those charges made prior to the student’s withdrawal (for example, for a change in enrollment status unrelated to the withdrawal). This also applies to situations where the institution charged the student for classes in multiple modules, but the denominator of the R2T4 calculation only consists of the days in a single module. [Guidance issued 08/20/2021]

 

 

 

 

 



   
Last Modified: 09/10/2021