Chapter 3

Return of Title IV Funds Case Studies - Part 2

Case Studies 6 and 7: Thompson S. Hunter

A student officially withdraws, returns, and withdraws again while receiving Title IV grants at a school that uses a term-based modular course structure, measures academic progress in credit hours, and performs its return calculations on a payment period basis.

Case Study 8: Eli Kraut

A student officially withdraws and is receiving Title IV grants at a school that uses a nonterm modular course structure, measures academic progress in credit hours, and performs its return calculations on a payment period basis.

Case Study 9: Baker Jeffries

A student officially withdraws, returns within 180 days, and withdraws again while receiving Title IV grants at a school that uses a nonterm modular course structure, measures academic progress in credit hours, and performs it return calculations on a payment period basis.

Case Study 6: Thompson S. Hunter

Here is an example of when a student receives Title IV grants at a school and officially withdraws. The school utilizes a term-based modular course structure, measures academic progress in credit hours and performs its Title IV return calculations on a payment period basis.

Learning Objectives

Learn to complete Steps 1–10 of the Treatment of Title IV Funds When a Student Withdraws from a Credit-Hour Program worksheet and be able to:

  • determine whether or not the student must be considered as withdrawn;

  • determine the total number of days the student was in attendance;

  • recalculate the student’s eligibility for Pell and Campus-Based funds;

  • calculate the percentage of the payment period the student completed;

  • calculate both the percentage and the amount of Title IV aid earned by the student;

  • determine either that the student is due a post-withdrawal disbursement (PWD) of Title IV aid or that Title IV aid must be returned; and

  • determine the amount to be offered to the student or returned.

School Profile

Las Vegas School of Digital Journalism (LSDJ) is a public residential institution that utilizes a term-based modular course structure and measures academic progress in credit hours.

Academic Year/ Period of Enrollment

2 semesters/32 weeks and 24 semester hours

Payment Period

1 semester/ 117 calendar days

Period Start Date

August 22

Period End Date

December 16

Institutionally Scheduled Break

Yes

Required to Take Attendance

No

Period used in Return calculation

Payment Period

Scheduled starting and ending dates for modules within the term.

Start

Start Dates
August 22
September 19
October 17
November 14

End

End dates
September 16
October 14
November 11
December 16

A scheduled break begins after the last class on Friday, November 18. Classes resume on Monday, November 28. The scheduled break is nine days long.

Though it is not a school that is required to take attendance, LSDJ has a school policy of using a student’s last date of attendance at an academically related activity as the withdrawal date when a student withdraws from a program offered in modules.

Student Profile

Thompson Hunter is an independent, third-year student enrolled at LSDJ for 12 credits offered in four modules. In each module, a student is enrolled in one course that begins and ends on a fixed date. In Thompson’s case, each course is worth three credits.

Charges to Thompson’s account for the payment period are as follows:

Tuition and fees

School Authorized to Credit Account for Other Charges:

$ 1,200.00/12 credits

Yes (all charges)

Thompson’s financial aid package is based on the following academic year (9-month budget):

Expense type
Tuition
Room
Board
Books
Personal Expenses
Travel
dollar amount
$ 2,400.00
$ 2,800.00
$ 1,600.00
$ 800.00
$ 800.00
$ 800.00

Thompson’s financial aid package included the following annual awards:

Award label
Pell Grant
FSEOG
award amount
$ 5,550.00
$ 3,650.00

All of Thompson’s financial aid for the first payment period (one-half his annual awards) was disbursed on the first day of classes.

Discussion

On the first day of the period, August 22, Thompson received the following disbursements to his student account (school uses the aggregate method to match FSEOG):

award label
Pell Grant
FSEOG
award amount
$ 2,775.00
$ 1,825.00

On October 17, Thompson comes to see you. He tells you that his dog Gonzo has just had 10 puppies. He fears that if he’s not around to help her, something terrible might happen to the puppies, and he doesn’t want to deal with the self-loathing that would result. He feels it is best if he withdraws from the first semester now.

When a student withdraws from one of a series of modules in a term-based program, a school must first determine whether or not the student must be treated as a withdrawal. In order to do so, the school must answer three questions:

  1. After beginning attendance in the payment period or period of enrollment, did the student cease to attend or fail to begin attendance in a course he or she was scheduled to attend?

    If the answer is no, this is not a withdrawal. If the answer is yes, go to question 2.

    In Thompson’s case, the answer to Question 1 is Yes; you go on to Question 2.

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

    If the answer is yes, this is not a withdrawal; (Note, however that other regulatory provisions concerning recalculation may apply.) If the answer is no, go to question 3.

    In Thompson’s case, the answer to Question 2 is No; you go on to Question 3.

  3. Did the student confirm attendance in a course in a module beginning later in the period?

    If the answer is yes, this is not a withdrawal, unless the student does not return. If the answer is no, this is a withdrawal, and the Return of Title IV Funds requirements apply.

    In Thompson’s Case, the answer is No; you must treat Thompson as a withdrawal.

Therefore, though Thompson completed the first two modules in the semester, since he doesn’t intend on returning to a module in this semester, the revised Return regulations require that LSDJ treat him as a withdrawn student.

Because Thompson failed to begin attendance in all of the classes on which his Pell Grant was based, before performing the required Return calculation, LSDJ must recalculate Thompson’s Pell based on his enrollment in just the two modules he began—six credits or half time. Thompson’s scheduled annual Pell award as a half-time student is $2,775. His revised first semester award is $1,388.00. LSDJ must return $1,387.00 (the difference between Thompson’s initial Pell disbursement of $2,775.00 and his new award of $1,388.00), and include only his new award of $1,388.00 in the Title IV return calculation. The school returns the $1,387.00 through G5 and reduces Thompson’s Pell Grant in COD to $1,388.00.

In addition, since Thompson was receiving Campus-Based aid (FSEOG), the school has to recalculate his eligibility for Campus-Based funds, eliminating the costs attributable to the modules that he did not begin attending to see whether a reduction of the Campus-Based aid is necessary. Based on a revised COA of $3,600.00 for the fall semester and revised Pell Grant of $1,388.00, Thompson’s remaining firstsemester need is $2,212.00. That is more than his FSEOG of $1,825.00. Therefore, LSDJ does not need to reduce Thompson’s FSEOG award before performing the Title IV return calculation.

LSDJ performed an R2T4 calculation using Thompson’s last day of attendance of October 14 as his withdrawal date (as per school policy); $1,388.00 as the amount of Pell Grant disbursed; and $1,825.00 as the amount of FSEOG funds disbursed. On October 24, LSDJ returned the funds for which it was responsible to the appropriate programs, and made the appropriate adjustments in COD.

Solution

Per school policy, Thompson’s withdrawal date is his last day of attendance at an academically related activity as determined from the school’s attendance records, October 14.

At the beginning of the semester, the following awards were posted to Thompson’s account at LSDJ.

award name
Pell Grant
FSEOG
award amount
$ 2,775.00
$ 1,825.00

Step 1: Student’s Title IV Aid Information

Box A.

After recalculating and returning the Pell Grant funds for which Thompson was ineligible, the Title IV grant aid disbursed was

labels
Pell Grant
FSEOG
A. =
amount
$ 1,388.00
$ 1,825.00
$ 3,213.00
Box B.

Net Title IV loans that could have been disbursed = $ 0.00.

Box C.

Title IV grants that could have been disbursed = $ 0.00.

Box D.

Title IV loans that could have been disbursed = $ 0.00.

Box E.

Total Title IV aid disbursed for the payment period = A + B = 3,213.00 + 0.00 = $ 3,213.00.

Box F.

Total Title IV grant aid disbursed and could have been disbursed for the payment period = A + C = 3,213.00 + 0.00 = $ 3,213.00.

Box G.

Total Title IV aid disbursed and could have been disbursed for the payment period = A + B + C + D = 3,213.00 + 0.00 + 0.00 + 0.00 = $3,213.00.

Step 2: Percentage of Title IV Aid Earned

LSDJ has an institutional policy of using the last date of attendance in an academically related activity as determined from its attendance records as the withdrawal date for students who cease attendance before completing more than 60 percent of the payment period. Thompson’s last date of attendance was October 14.

  1. Payment Period start date = August 22.

  2. Payment Period end date = December 16.

  3. Date of withdrawal = October 14.

  4. Percentage of payment period completed

    • Number of calendar days completed = 54

    • Number of calendar days in the payment period = 108 (117 – 9 day scheduled break)

    • 54 days ÷ 108 days = 0.50. percentage of payment period completed = 50.0%

Box H.

Because this percentage is 60% or less, the percentage of Title IV aid earned = 50.0%.

Step 3: Amount of Title IV Aid Earned by the Student

Box I.

50.0% (percentage of Title IV aid earned from Box H) × $3,213.00 (Total of the Title IV aid disbursed and could have been disbursed for the payment period or period of enrollment from Box G) = $1,606.50. Amount of Title IV aid earned by the student = $1,606.50.

Step 4: Total Title IV Aid to be Disbursed or Returned

Box J.

Because the total Title IV aid earned (Box I) is less than the total Title IV aid disbursed (Box E), no post-withdrawal disbursement is due, and we proceed to Box K.

Post-withdrawal disbursement = NA.

Box K.

Because the total Title IV aid disbursed (Box E) is greater than the total Title IV aid earned (Box I), Title IV aid must be returned.

$3,213.00 (Box E) – $1,606.50 (Box I) = $1,606.50. Title IV Aid to be returned = $1,606.50.

Step 5: Amount of Title IV Aid Due from the School

Box L.

The institutional charges on Thompson’s account are the charges initially assessed for the payment period. Note that books and supplies are not included because Thompson had an opportunity to purchase them elsewhere, and did.

expense types
Tuition and fees
Room
Board
Box L =
expense amount, last line is sum
$ 1,200.00
$ 1,400.00
$ 800.00
$ 3,400.00
Box M.

Subtract the percentage of Title IV earned from Box H (50.0%) from 100.0%. 100% – 50.0% = 50.0%. percentage of Title IV aid unearned = 50.0%.

Box N.

Calculate the amount of unearned charges. $3,400.00 (institutional charges from Box L) × 50.0% (% of Title IV aid unearned from Box M) = $1,700.00.

Amount of unearned institutional charges = $1,700.00.

Box O.

Compare the amount of Title IV aid to be returned (Box K) to unearned institutional charges (Box N), and enter the lesser amount in Box O.

box label
Box K =
Box N =
box amount
$ 1,606.50
$ 1,700.00

Amount of unearned Title IV aid due from the school = $1,606.50.

Step 6: Return of Funds by the School

Box P.

Thompson received a recalculated Pell Grant disbursement of $1,388.00. Since $1,388.00 is less than the $1,606.50 (Box O) the school must return, the school must return the $1,388.00 to the Pell Grant Program and an additional $218.50 (1,606.50 – 1,388.00) to the FSEOG program through the G5 system. The school must also reduce Thompson’s Pell Grant in COD to $0.00.

The school must return any unearned funds within 45 days from the date of the school’s determination that Thompson withdrew.

Step 7: Initial Amount of Unearned Title IV Aid Due from Student

Box Q.

Subtract the amount of Title IV aid the school must return ($1,606.50 from Box O) from the total amount of Title IV aid that is to be returned ($1,606.50 from Box K) to find the initial amount of Title IV aid due from the student. $1,606.50 – $1,606.50 = $0.00.

Box Q =

$ 0.00

Because Box Q is $0.00, no further calculation is needed.

Case Study 7: The Return of Thompson S. Hunter

Here is an example of when a student receiving Title IV grants officially withdraws, but returns within the payment period and withdraws again. The school utilizes a term-based modular course structure, measures academic progress in credit hours and performs its Title IV return calculations on a payment period basis.

Learning Objectives

Learn to complete Steps 1–10 of the Treatment of Title IV Funds When a Student Withdraws from a Credit-Hour Program worksheet, and be able to:

  • identify the steps that must be taken when a student who withdrew from a term-based program offered in modules returns within the payment period;

  • determine the numerator and denominator when calculating the percentage of the payment period completed for a student who withdraws, returns and withdraws again.

  • recalculate the student’s eligibility for Pell and Campus-Based funds;

  • calculate the percentage of the payment period the student completed, and the percentage and the amount of Title IV aid earned by the student;

  • determine if the student is due a post-withdrawal disbursement (PWD) of Title IV aid or that Title IV aid must be returned, and if so, how much the school must return and

  • determine the amount to be offered to the student or returned by him.

School Profile

Las Vegas School of Digital Journalism (LSDJ) is public residential institution that utilizes a term-based modular course structure and measures academic progress in credit hours.

Academic Year/Period of Enrollment

Payment Period

Period Start Date

Period End Date

Institutionally Scheduled Break

Required to Take Attendance

Period used in Return calculation

2 semesters/32 weeks and 24 semester hours

1 semester/117 calendar days

August 22

December 16

Yes

No

Payment Period

Scheduled starting and ending dates for modules within the term.

Start

Start date column
August 22
September 19
October 17
November 14

End

end date column
September 16
October 14
November 11
December 16

A scheduled break begins after the last class on Friday, November 18. Classes resume on Monday, November 28. The scheduled break is nine days long.

Though it is not a school that is required to take attendance, LSDJ has a school policy of using a student’s last date of attendance at an academically related activity as the withdrawal date when a student withdraws from a program offered in modules.

Student Profile

Thompson Hunter is an independent third-year student enrolled at LSDJ for 12 credits offered in four modules. In each module a student is enrolled in one course that begins and ends on a fixed date. In Thompson’s case, each course is worth three credits.

Charges to Thompson’s account for the payment period are as follows:

Tuition and fees

School Authorized to Credit Account for Other Charges:

$ 1,200.00/12 credits

Yes (all charges)

Thompson’s financial aid package is based on the following academic year (9-month budget):

expense labels column
Tuition
Room
Board
Books
Personal Expenses
Travel
dollar amount column
$ 2,400.00
$ 2,800.00
$ 1,600.00
$ 800.00
$ 800.00
$ 800.00

Thompson’s financial aid package included the following annual awards:

award type column
Pell Grant
FSEOG
award amount
$ 5,550.00
$ 3,650.00

All of Thompson’s financial aid for the first payment period (one-half his annual awards) was disbursed on the first day of classes.

Discussion

On November 11, Thompson Hunter (the student from Case Study 6) walks into your office with the news that his wife Barbara Ann has quit her acting job in LA and moved back to Las Vegas. Longing for a normal family life, Barbara Ann is more than happy to care for Gonzo and the puppies. Thompson would like to re-enter the program when the fourth module begins on November 14.

When Thompson returns for module four, 34 CFR 668.22(a)(2)(iii)(A) applies. That regulation provides that, if a student withdraws from a term-based credit-hour program offered in modules and re-enters the same program prior to the end of the payment period, the student is treated as if he or she did not cease attendance for purposes of determining the student’s aid awards for the period. The student is considered to be in the same payment period he or she was in at the time of the withdrawal and retains his or her original Title IV eligibility for that payment period, provided the student’s enrollment status continues to support the same amount of those funds. To do this, the school must:

  • recalculate Thompson’s Title IV program eligibility based upon enrollment in modules 1, 2, and 4 and then re-disburse any Title IV, HEA program funds that had been disbursed and then returned under the Return of Title IV Funds provisions, adjusting, if necessary, for any change in his enrollment status;

  • disburse any Title IV, HEA program funds for which Thompson was otherwise eligible that had not yet been disbursed at the time he withdrew, adjusting for the change in enrollment status; and

  • cancel any Title IV overpayments assessed Thompson as a result of the prior withdrawal.

When Thompson returns in module four, the three credits for that module are added to the six credits that Thompson completed previously. Nine credits at LSDJ are the minimum number required for three-quarter-time enrollment status. Therefore, the school must recalculate Thompson’s eligibility for Title IV assistance as a threequarter time student. Thompson’s scheduled annual Pell award as a three-quarter-time student is $4,163.00, and his one-semester award is $2,081.50.

After recalculating Thompson’s eligibility from full time to half time when he withdrew previously, the school returned $1,387.00 (the difference between Thompson’s initial Pell disbursement of $2,775.00 and his halftime award of $1,388.00). The school then included only his new award of $1,388.00 in the Return calculation and returned the entire amount as a result of the calculation. The school also reduced his Pell award in COD to $0.00. When Thompson returns, the school must once again adjust his award in COD (this time to his three-quarter-time award of $2,081.50) and draw down and disburse $2,081.50 to his account.

In addition, the school has to recalculate Thompson’s eligibility for Campus-Based funds, adding the costs attributable to the additional module that he has begun attending, to see whether a modification of his Campus-Based aid is necessary. Based on a revised COA of $4,100.00 for the fall semester and revised Pell Grant of $2,081.50, Thompson’s remaining first-semester need is $2,018.50. That is greater than his initial FSEOG award of $1,825.00. Therefore, since it has not already awarded the $218.50 that it returned previously to another eligible student, the school re-awards and disburses the $218.50 in FSEOG funds to Thompson.

When the aid officer reviews the results of the previous Title IV return calculation, he finds that Thompson had not been required to return any Title IV funds; therefore, there are no student overpayments to cancel.

On the first day of module four, November 14, LSDJ made the following disbursements to his student account (school uses the aggregate method to match FSEOG):

award type column
Pell Grant
FSEOG
award dollar amount
$ 2,081.50
$ 218.50 (restoring his total to $1,825)

After class on December 5, Thompson once again comes to see you. He says that his uncle Raoul (born in England under mysterious circumstances) has just discovered that he is in line to be the Duke of Marlboro. Raoul must go to England immediately to claim the title, and he’s willing to cover the cost of Thompson’s traveling with him to the investiture. Therefore, Thompson has decided to withdraw immediately.

When a student withdraws from one of a series of modules in a term-based program, a school must first determine whether or not the student must be treated as a withdrawal. In order to do so, the school must answer three questions:

  1. After beginning attendance in the payment period or period of enrollment, did the student cease to attend or fail to begin attendance in a course he or she was scheduled to attend?

    If the answer is no, this is not a withdrawal. If the answer is yes, go to question 2.

    In Thompson’s case, the answer to Question 1 is Yes; you go on to Question 2.

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

    If the answer is yes, this is not a withdrawal. (Note, however, that other regulatory provisions concerning recalculation may apply.) If the answer is no, go to question 3.

    In Thompson’s case, the answer to Question 2 is No; you go on to Question 3.

  3. Did the student confirm attendance in a course in a module beginning later in the period? (If this were a non-standard term or nonterm program, this would have to be no later than 45 calendar days after the end of the module the student ceased attending.)

    If the answer is yes, this is not a withdrawal unless the student does not return. If the answer is no, this is a withdrawal, and the Return of Title IV Funds requirements apply.

    In Thompson’s case, the answer is No; you must treat Thompson as a withdrawal.

Thompson began attendance in all of the classes on which his Pell Grant was based (modules 1,2, and 4). Therefore, the school did not need to recalculate Thompson’s revised Pell Grant. In addition, since Thompson began attendance in all of the classes on which his Campus-Based aid (FSEOG) was based, the school did not have to recalculate his eligibility for Campus-Based funds.

Solution

Per school policy, Thompson’s withdrawal date is his last day of attendance at an academically related activity as determined from the school’s attendance records, December 5.

Step 1: Student’s Title IV Aid Information

Box A.

Since Thompson had begun all modules (classes) on which his Pell and Campus-Based aid was based, the Title IV grant aid disbursed was –

award label column
Pell Grant
FSEOG
A. =
dollar amount column
$ 2,081.50
$ 1,825.00
$ 3,906.50
Box B.

Net Title IV loans that could have been disbursed = $ 0.00.

Box C.

Title IV grants that could have been disbursed = $ 0.00.

Box D.

Title IV loans that could have been disbursed = $ 0.00.

Box E.

Total Title IV aid disbursed for the payment period = A + B = 3,906.50 + 0.00 = $ 3,906.50.

Box F.

Total Title IV grant aid disbursed and could have been disbursed for the payment period = A + C = 3,906.50 + 0.00 = $ 3,906.50.

Box G.

Total Title IV aid disbursed and could have been disbursed for the payment period = A + B + C + D = 3,906.50 + 0.00 + 0.00 + 0.00 = $3,906.50

Step 2: Percentage of Title IV Aid Earned

Though it is not a school that is required to take attendance, LSDJ has a school policy of using a student’s last date of attendance at an academically related activity as the withdrawal date when a student withdraws from a program offered in modules.

The total number of days in the payment period is the original 108 days. While the student did not begin module three, since module three was included in the original payment period or period of enrollment and used to determine the amount of Title IV, HEA funds eligibility, the days from module three are included in the denominator.

The total number of completed calendar days in the period reflects the completed days in modules one, two, and four. From the previous Title IV return calculation, we know that Thompson completed 54 days in modules one and two. He completed 13 days in module 4 (22 days less the 9-day scheduled break). The total number of days completed (the days completed in modules one, two, and four) are the sum of the days completed during each period or 67 days (54 + 13).

  1. Payment Period start date = August 22.

  2. Payment Period end date = December 16.

  3. Date of withdrawal = December 5.

  4. Percentage of payment period completed

    • Number of calendar days completed in modules one, two, and four = 67

    • Number of calendar days in the payment period = 108 (117 – 9-day scheduled break)

    • 67 days ÷ 108 days = 0.62. Percentage of payment period completed = 62.0%

Box H.

Because this percentage is greater than 60%, the percentage of Title IV aid earned = 100.0%. Note that although no return is required, the school must complete Step 3 in order to determine whether 100% of his aid has been disbursed or Thompson was due a post-withdrawal disbursement.

Percentage of Title IV aid earned = 100.00%

Step 3: Amount of Title IV Aid Earned by the Student

Box I.

100.0% (percentage of Title IV aid earned from Box H) X $3,906.50. (Total of the Title IV aid disbursed and could have been disbursed for the payment period or period of enrollment from Box G) = $3,906.50.

Amount of Title IV aid earned by the student = $3,906.50.

No further action is necessary.

Case Study 8: Eli Kraut

Here is an example of when a student receiving Title IV grants and loans officially withdraws and is not scheduled to return within 45 days. The school utilizes a nonterm modular course structure, measures academic progress in credit hours and performs its Title IV return calculations on a payment period basis.

Learning Objectives

Learn to complete Steps 1–10 of the Treatment of Title IV Funds When a Student Withdraws from a Credit-Hour Program worksheet, and be able to:

  • determine whether or not a student must be considered a withdrawal;

  • determine if it is necessary, and if so, recalculate the student’s eligibility for Pell and Campus-Based funds;

  • determine the total number of days the student was in attendance, and the numerator and denominator when calculating the percentage of the payment period completed;

  • calculate the percentage of the payment period the student completed, and both the percentage and the amount of Title IV aid earned by the student;

  • determine either that the student is due a post-withdrawal disbursement (PWD) of Title IV aid or that Title IV aid must be returned; and

  • determine the amount to be offered to the student or returned.

School Profile

The Giant School of Sports Medicine (GSSM) is a private, for profit institution that utilizes a nonterm modular course structure and measures academic progress in credit hours.

Academic Year/Period of Enrollment

Payment Period

Period Start Date

Period End Date

Institutionally Scheduled Break

Required to Take Attendance

Period Used in Return Calculation

24 credits/32 weeks

12 credit hours/4 modules (each of 4 weeks duration)/16 weeks

August 1

November 18

No

No

Payment Period

Scheduled starting and ending dates for modules within the payment period.

Start

Start date column
August 1
August 29
September 26
October 24

End

End date column
August 26
September 23
October 21
November 18
Student Profile

Eli Kraut is a dependent, fourth-year student enrolled at GSSM for 12 credits offered in four modules. In each four-week module, a student enrolls in one course that begins and ends on a fixed date. In Eli’s case, each course is worth three credits.

Charges to Eli’s account for the payment period are as follows:

Tuition and fees

School Authorized to Credit Account for Other Charges:

$ 3,200.00/12 credits

Yes (all charges)

Eli’s financial aid package is based on the following nine month academic year cost of attendance (COA).

Expense label column
Tuition
Room
Board
Books
Personal Expenses
Travel
Total COA
Dollar amount column
$ 6,400.00
$ 3,200.00
$ 3,200.00
$ 1,600.00
$ 3,200.00
$ 800.00
$ 18,400.00

Eli’s financial aid package included the following annual awards:

award label column
Pell Grant
FSEOG
Subsidized Direct Loan
Federal Work Study (FWS)
Award dollar amount
$ 5,550.00
$ 4,000.00
$ 5,500.00
$ 3,350.00

Except for his FWS award, all of Eli’s financial aid for the first payment period (one-half his annual awards) was disbursed on the first day of classes.

Discussion

On the first day of the period, August 1, Eli received the following disbursements to his student account (school uses the aggregate method to match FSEOG):

award label column
Pell Grant
FSEOG
Net Subsidized Direct Loan
award dollar amount
$ 2,775.00
$ 2,000.00
$ 2,700.00

On August 25, Eli comes to see you. He tells you that his twin brother, Jake, has just won an all-expenses paid Mediterranean cruise for two and has invited Eli to accompany him on the cruise. Eli has decided not to miss this chance of a lifetime. He intends to drop modules two and three, and return for the fourth module on October 24. On August 26, Eli completes module one and withdraws.

When a student withdraws from one of a series of modules in a nonterm-based program, a school must first determine whether or not the student must be treated as a withdrawal. In order to do so, the school must answer three questions:

  1. After beginning attendance in the payment period or period of enrollment, did the student cease to attend or fail to begin attendance in a course he or she was scheduled to attend?

    If the answer is no, this is not a withdrawal. If the answer is yes, go to question 2.

    In Eli’s case, the answer to Question 1 is Yes; you go on to Question 2.

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

    If the answer is yes, this is not a withdrawal. (Note, however that other regulatory provisions concerning recalculation may apply.) If the answer is no, go to question 3.

    In Eli’s case, the answer to Question 2 is No; you go on to Question 3.

  3. Did the student confirm attendance in a course in a module beginning later in the period? For nonterm and nonstandard term programs, this must be no later than 45 calendar days after the end of the module the student ceased attending.

If the answer is yes, this is not a withdrawal unless the student does not return. If the answer is no, this is a withdrawal, and the Return of Title IV Funds requirements apply.

Note: CFR 34 668.22(a)(2)(i)(C) provides that a student in a nonterm or nonstandard term program is considered to have withdrawn for Title IV purposes if the student is not scheduled to begin another course within a payment period or period of enrollment for more than 45 calendar days, unless the student is on an approved leave of absence. 34 CFR 668.22(a)(2)(ii)(A)(2) provides that, for a nonterm or nonstandard term program, an institution must treat as a withdrawal a student who ceases attendance in a module, notwithstanding a student’s confirmation of attendance in a future module in the payment period or period of enrollment if that module does not begin within 45 days of the end of the module the student ceased attending. (For additional information see Withdrawals from programs offered in modules in Chapter 2.)

The module in which Eli will be returning (module 4) does not start until October 24. That is 59 days from August 26, the end of the first module. Therefore, in Eli’s case, the answer to Question 3 is No; you must treat Eli as a withdrawal.

Because Eli failed to begin attendance in all of the classes on which his Title IV aid was based, before performing the required Return calculation GSSM must recalculate Eli’s eligibility for Title IV funds based on his enrollment in just the one module he began— three credits, or less than half time.

Note: Pell Grant awards for students in clock-hour programs and programs without terms are always based on the Payment Schedule for Determining Full-Time Awards. Therefore, a school does not have to recalculate a Pell Grant when a student attending a nonterm program or clock-hour program withdraws.

The school does have to recalculate Eli’s eligibility for Campus-Based aid (FSEOG and FWS), eliminating the costs attributable to the modules that he did not begin attending, to see whether a reduction of the Campus-Based aid was necessary. After eliminating the expenses associated with the period of non-attendance, the school determined that the COA (for Campus-Based purposes) associated with Eli’s enrollment in the one module was $2,600.00. The loan funds that Eli had already received (and for which his eligibility does not have to be recalculated—$2,700.00) plus his Pell Grant ($2,775.00), plus the $500.00 in FWS Eli has earned to date equal $5,975.00. Since $5,975.00 exceeds Eli’s revised COA of $2,500.00, the aid officer determined that Eli was not eligible for any FSEOG funds, so the school had to reduce Eli’s FSEOG award to $0.00 and either award the $2,000.00 in FSEOG funds to another eligible student or return them to ED. Note that Pell Grants and earned FWS funds are never reduced to address an overpayment.

Note: Any time a student enrolled in a clock-hour or nonterm program changes his or her enrollment status, the school must recalculate the student’s COA to determine if the student’s eligibility for Campus -Based funds has changed. The school may not include in the COA costs associated with any classes the student failed to begin. Moreover, when a student enrolled in a clock-hour or nonterm program withdraws, a school that calculates Returns on a period of enrollment basis may not include costs associated with any future payment period for which the student has not confirmed attendance at the time of withdrawal and that does not start within 45 days in the student’s COA.

GSSM performed an R2T4 calculation using Eli’s last day of attendance of August 26 as his withdrawal date; $2,775.00 as the amount of Pell Grant disbursed; $0.00 as the amount of FSEOG funds disbursed; and $2,700.00 as the amount of Subsidized Direct Loan funds disbursed. On September 4, GSSM returned the funds for which it was responsible to the appropriate programs.

Solution

Eli’s withdrawal date is his last day of attendance at an academically related activity as determined from the school’s attendance records, August 26.

At the beginning of the payment period, the following awards were posted to Eli’s account at GSSM.

award label column
Pell Grant
FSEOG
Net Subsidized Direct Loan
award amount column
$ 2,775.00
$ 2,000.00
$ 2,700.00

Step 1: Student’s Title IV Aid Information

Box A.

After recalculation, the Title IV grant aid disbursed was

award label
Pell Grant
FSEOG
A. =
amount column
$ 2,775.00
$ 0.00
$ 2,775.00
Box B.

Net Title IV loans disbursed

loan label
Subsidized Direct Loan
B. =
amount column
$ 2,700.00
$ 2,700.00
Box C.

Title IV grants that could have been disbursed = $ 0.00.

Box D.

Title IV loans that could have been disbursed = $ 0.00.

Box E.

Total Title IV aid disbursed for the payment period = A + B = 2,775.00 + 2,700.00 = $ 5,475.00.

Box F.

Total Title IV grant aid disbursed and could have been disbursed for the payment period = A + C = 2,775.00 + 0.00 = $ 2,775.00.

Box G.

Total Title IV aid disbursed and could have been disbursed for the payment period = A + B + C + D = 2,775.00 + 2,700.00 + 0.00 + 0.00 = $5,475.00.

Step 2: Percentage of Title IV Aid Earned

For Title IV purposes, Eli’s withdrawal date is August 26, the day he dropped modules two and three and notified the school that he would not be returning until the start of module four. Note that because Eli didn’t drop modules two and three before withdrawing, the days in those modules are included in the number of days in the payment period.

  1. Payment Period start date = August 1.

  2. Payment Period end date = November 18.

  3. Date of withdrawal = August 26.

  4. Percentage of payment period completed

    • Number of calendar days completed = 26

    • Number of calendar days in the payment period = 110

    • 26 days ÷ 110 days = 0.2363. Percentage of payment period completed = 23.6%

Box H.

Because this percentage is less than or equal to 60%, the percentage of Title IV aid earned in Box H = 23.6%.

Step 3: Amount of Title IV Aid Earned by the Student

Box I.

23.6% (percentage of Title IV aid earned from Box H) X $5,475.00 (Total of the Title IV aid disbursed and could have been disbursed for the payment period or period of enrollment from Box G) = $1,292.10. Amount of Title IV aid earned by the student = $1,292.10.

I. =

$1,292.10

Step 4: Total Title IV Aid to be Disbursed or Returned

Box J.

Because the total Title IV aid earned (Box I) is less than the total Title IV aid disbursed (Box E), no post-withdrawal disbursement is due, and we proceed to Box K.

Post-withdrawal disbursement = NA.

Box K.

Because the total Title IV aid disbursed (Box E) is greater than the total Title IV aid earned (Box I) Title IV aid must be returned.

$5,475.00 (Box E) – $1,292.10 (Box I) = $4182.90. Title IV Aid to be returned = $4182.90.

K. =

$4182.90.

Step 5: Amount of Title IV Aid Due from the School

Box L.

The institutional charges on Eli’s account are the charges initially assessed for the payment period. Note that books and supplies are not included because Eli had an opportunity to purchase them elsewhere, and did.

charge labels
Tuition and fees
Room
Board
Box L =
amount column
$ 3,200.00
$ 1,600.00
$ 1,600.00
$ 6,400.00
Box M.

Subtract the percentage of Title IV earned from Box H (23.6%) from 100.0%. 100% – 23.6% = 76.4%. Percentage of Title IV aid unearned = 76.4%.

M =

76.4%

Box N.

Calculate the amount of unearned charges. $6,400.00 (institutional charges from Box L) X 76.4% (% of Title IV aid unearned from Box M) = $4,889.60. Amount of unearned institutional charges = $4,889.60.

N =

$ 4,889.60

Box O.

Compare the amount of Title IV aid to be returned (Box K) to unearned institutional charges (Box N), and enter the lesser amount in Box O.

box name column
Box K =
Box N =
dollar amount column
$ 4,182.90
$ 4,889.60

Amount of unearned Title IV aid due from the school = $4182.90.

O =

$ 4,182.90

Step 6: Return of Funds by the School

Box P.

The amount of unearned Title IV aid due from the school is $4182.90 (Box O), and Title IV loans are returned before Title IV grants. Since Eli received a Net Subsidized Direct Loan of $2,700.00, the school returns the entire $2,700.00 to the Direct Loan Program.

The school also returns $1,482.90 ($4182.90 [from Box O] – $2,700.00 [from Box P]) to the Pell Grant Program.

The school must return any unearned funds within 45 days from the date of the institution’s determination that Eli withdrew.

Step 7: Initial Amount of Unearned Title IV Aid Due from Student

Box Q.

Subtract the amount of Title IV aid the school must return ($4,182.90 from Box O) from the total amount of Title IV aid that is to be returned ($4,182.90 from Box K) to find the initial amount of Title IV aid due from the student. $4,182.90 – $4,182.90 = $0.00.

Q =

$ 0.00

There is no unearned aid due from the student, so the Title IV return calculation ends here.

Case Study 9: Baker Jeffries

An independent, fourth-year student receiving Title IV grants and loans at a school that utilizes a nonterm modular course structure, measures academic progress in credit hours, and performs its return calculations on a payment period basis, officially withdraws, returns within 180 days, and withdraws again.

Learning Objectives

Learn to complete Steps 1–8 of the Treatment of Title IV Funds When a Student Withdraws from a Credit-Hour Program worksheet and be able to:

  • determine the total number of days the student was in attendance;

  • determine the total number of days in the payment period;

  • calculate the percentage of the payment period the student completed;

  • calculate both the percentage and the amount of Title IV aid earned by the student;

  • determine either that the student is due a post-withdrawal disbursement (PWD) of Title IV aid or that Title IV aid must be returned; and

  • determine the amount to be offered to the student or returned.

School Profile

Chula University (CU) is a non-residential postsecondary institution that utilizes a nonterm modular course structure and measures academic progress in credit hours.

Academic Year/Period of Enrollment

Payment Period

Period Start Date

Period End Date

Institutionally Scheduled Break

Required to Take Attendance

Period used in Return calculation

24 credits/32 weeks

12 credit hours/4 modules (each of 4 weeks duration)/16 weeks

January 9

April 27

None

No

Payment Period

Scheduled starting and ending dates for modules within the calendar year. At each starting point all modules are offered.

Start

End

January 9

February 3

February 6

March 2

March 5

March 30

April 2

April 27

April 30

May 25

May 28

June 22

June 25

July 20

July 23

August 17

August 20

September 14

September 17

October 12

October 15

November 9

November 12

December 7

Student Profile

Baker Jeffries is an independent, fourth-year student enrolled at CU for 12 credits offered in four three-credit modules. CU anticipates that Baker, as do most of the students at CU, will complete each of the modules in four weeks, and the payment period in 16 weeks.

Charges to Baker’s account for the payment period are as follows:

Tuition and fees

School Authorized to Credit Account for Other Charges:

$ 6,000.00/12 credits

Yes (all charges)

Baker’s financial aid package is based on the following eight-month academic year cost of attendance (COA).

expense label column
Tuition
Room
Board
Books
Personal Expenses
Travel
Total COA
dollar amount column
$ 12,000.00
$ 3,200.00
$ 3,200.00
$ 1,200.00
$ 3,200.00
$ 800.00
$ 23,600.00

Baker’s financial aid package included the following annual awards:

award label column
Pell Grant
FSEOG
Subsidized Direct Loan
Unsubsidized Direct Loan
Federal Work Study (FWS)
award dollar amount
$ 5,550.00
$ 4,000.00
$ 5,500.00
$ 4,250.00
$ 4,500.00

Discussion

On the first day of the period, January 9, Baker received disbursements totaling $9,500.00 in Title IV assistance from the following programs to his student account (school uses the aggregate method to match FSEOG):

award label column
Pell Grant
FSEOG
Net Subsidized Direct Loan
Net Unsubsidized Direct Loan
award dollar amount
$ 2,775.00
$ 2,000.00
$ 2,700.00
$ 2,025.00

On January 27, you are notified by the registrar that Baker has dropped module 2. Then, on February 3, after completing the last class in module 1, Baker comes to see you. He tells you that he’s been offered a job as a researcher on a project studying the terrapin species native to the brackish coastal swamps of Maryland and other southeastern states. Baker has decided to withdraw from school in order to accept the job.

When a student withdraws from one of a series of modules in a nonterm-based program, a school must first determine whether or not the student must be treated as a withdrawal. In order to do so, the school must answer three questions:

  1. After beginning attendance in the payment period or period of enrollment, did the student cease to attend or fail to begin attendance in a course he or she was scheduled to attend? If the answer is no, this is not a withdrawal. If the answer is yes, go to question 2.

    In Baker’s case, the answer to Question 1 is Yes; you go on to Question 2.

  2. When the student ceased to attend or failed to begin attendance in a course he or she was scheduled to attend, was the student still attending any other courses? If the answer is yes, this is not a withdrawal. (Note, however, that other regulatory provisions concerning recalculation may apply.) If the answer is no, go to question 3.

    In Baker’s case, the answer to Question 2 is No; you go on to Question 3.

  3. Did the student confirm attendance in a course in a module beginning later in the period? For nonterm and nonstandard term programs, this must be no later than 45 calendar days after the end of the module the student ceased attending. If the answer is yes, this is not a withdrawal, unless the student does not return. If the answer is no, this a withdrawal, and the Return of Title IV Funds requirements apply.

    In Baker’s case, the answer is No, and therefore you must consider Baker as a withdrawn student.

Because Baker failed to begin attendance in all of the classes on which his Title IV aid was based, before performing the required Title IV return calculation, CU must recalculate Baker’s eligibility for Title IV funds based on his enrollment in just the one module he began—three credits, or less than half time.

Note: Pell Grant awards for students in clock-hour programs and programs without terms are always based on the Payment Schedule for Determining Full-Time Awards. Therefore a school does not have to recalculate a Pell Grant when a student attending a nonterm program or clock-hour program withdraws.

The school does have to recalculate Baker’s eligibility for Campus-Based aid (FSEOG and FWS), eliminating the costs attributable to the modules that he did not begin attending, to see whether a reduction of the Campus-Based aid was necessary. After eliminating the expenses associated with the period of non-attendance, the school determined that the COA (for Campus-Based purposes) associated with Baker’s enrollment in the one module was $3,250.00.

The loan funds that Baker had already received (and for which his eligibility does not have to be recalculated—$4,725.00) plus his Pell Grant ($2,775.00), plus the $400.00 in FWS Baker has earned to date equal $7,900.00. Since $7,900.00 exceeds Baker’s revised COA of $3,250.00, the aid officer determined that Baker was not eligible for any FSEOG funds, so the school had to reduce Baker’s FSEOG award to $0.00 and either award the $2,000.00 in FSEOG funds to another eligible student or return them to ED. (Note that Pell Grants and earned FWS funds are never reduced to address an overpayment.)

Note: Any time a student enrolled in a clock-hour, nonterm program, or nonstandard term program with terms that are not substantially equal changes his or her enrollment status, the school must recalculate the student’s COA to determine if the student’s eligibility for Campus-Based funds has changed. The school may not include in the student’s COA costs associated with any classes the student failed to begin. Moreover, when a student enrolled in a clock-hour, nonterm program, or non standard term program with terms that are not substantially equal withdraws, a school that calculates Returns on a period of enrollment basis may not include costs associated with any future payment period for which the student has not confirmed attendance at the time of withdrawal and that does not start within 45 days in the Student’s COA.

CU performed an R2T4 calculation using Baker’s last day of attendance of February 3 as his withdrawal date; $2,775.00 as the amount of Pell Grant disbursed; $0.00 as the amount of FSEOG funds disbursed; $2,700.00 as the amount of Subsidized Direct Loan funds disbursed; and $2,025.00 as the amount of unsubsidized loan funds disbursed. On February 17, CU returned the funds for which it was responsible to the appropriate programs.

Solution

At the beginning of the semester, the following awards were posted to Baker’s account at CU.

Award label column
Pell Grant
FSEOG
Subsidized Direct Loan
Unsubsidized Direct Loan
award dollar amount column
$ 2,775.00
$ 2,000.00
$ 2,700.00
$ 2,025.00

Step 1: Student’s Title IV Aid Information

Box A.

After recalculation, the Title IV grant aid disbursed was

Award label column
Pell Grant
FSEOG
A. =
award dollar amount column
$ 2,775.00
$ 0.00
$ 2,775.00
Box B.

Net Title IV loans disbursed

loan label
Net Subsidized Direct loan
Net Unsubsidized Direct
B. =
loan amount
$ 2,700.00
$ 2,025.00
$ 4,725.00
Box C.

Title IV grants that could have been disbursed = $ 0.00.

Box D.

Title IV loans that could have been disbursed = $ 0.00.

Box E.

Total Title IV aid disbursed for the payment period = A + B = 2775.00 + 4,725.00 = $ 7,500.00.

Box F.

Total Title IV grant aid disbursed and could have been disbursed for the payment period = A + C = 2,775.00 + 0.00 = $ 2,775.00.

Box G.

Total Title IV aid disbursed and could have been disbursed for the payment period = A + B + C + D = 2,775.00 + 4,725.00 + 0.00 + 0.00 = $7,500.00.

Step 2: Percentage of Title IV Aid Earned

For Title IV purposes, Baker’s withdrawal date is February 3, the day he informed the aid office that he was withdrawing.

  1. Payment Period start date = January 9.

  2. Payment Period end date = April 27.

  3. Date of withdrawal = February 3.

  4. Percentage of payment period completed

    Note: Because Baker dropped one module (module 2) of the course before he withdrew, the days following the end of module 1 (February 4) through the day prior to the start of module 3 (March 4)—30 days—are excluded from the total days used in determining the percentage of the period completed.

    • Number of calendar days completed = 26

    • Number of calendar days in the payment period = 80 (The 110 days in the original period less the 30 days from February 4 through March 4)

    • 26 days ÷ 80 days = 0.3250. Percentage of payment period completed = 32.5%

Box H.

Because this percentage is less than or equal to 60%, the percentage of Title IV aid earned in Box H = 32.5%.

Step 3: Amount of Title IV Aid Earned by the Student

Box I.

32.5% (percentage of Title IV aid earned from Box H) X $7500.00 (Total of the Title IV aid disbursed and could have been disbursed for the payment period or period of enrollment from Box G) = $2,437.50 Amount of Title IV aid earned by the student = $2,437.50 .

I. =

$2,437.50

Step 4: Total Title IV Aid to be Disbursed or Returned

Box J.

Because the total Title IV aid earned (Box I) is less than the total Title IV aid disbursed (Box E), no post-withdrawal disbursement is due, and we proceed to Box K.

Post-withdrawal disbursement = NA.

Box K.

Because the total Title IV aid disbursed (Box E) is greater than the total Title IV aid earned (Box I), Title IV aid must be returned.

$7500.00 (Box E) – $2,437.50 (Box I) = $5,062.50. Title IV Aid to be returned = $5,062.50.

K. =

$5,062.50

Step 5: Amount of Title IV Aid Due from the School

Box L.

The charges used in a Title IV return calculation are always the charges initially assessed by the school adjusted only for any courses or module the student dropped prior to the date the student withdrew Therefore, even though CU refunds the tuition Baker paid for the modules he did not start, the school must enter $4,500.00 in Step 5 of the Return calculation. (The $6,000.00 initially charged minus the $1,500.00 for module 2 that Baker dropped before withdrawing.) A $150.00 charge for books is included because Baker did not have the opportunity to purchase them elsewhere.

label
Tuition and fees
Books
L. =
dollar amount
$ 4,500.00
$ 150.00
$ 4,650.00
Box M.

Subtract the percentage of Title IV earned from Box H (32.5%) from 100.0%. 100% – 32.5% = 67.5%. Percentage of Title IV aid unearned = 67.5%.

M. =

67.5%

Box N.

Multiply the institutional charges from Box L ($4,650.00) by the percentage of unearned Title IV aid from Box M (67.5%) to find the amount of unearned charges $4,650.00 X 67.5% = $3,138.75. Amount of unearned = $3,138.75.

N. =

$3,138.75

Box O.

Compare the amount of Title IV aid to be returned (Box K) to unearned institutional charges (Box N), and enter the lesser amount in Box O.

box letter
K. =
N. =
box amount
$5,062.50
$3,138.75

Amount of unearned Title IV aid due from the school = $3,138.75.

Step 6: Return of Funds by the School

Box P.

The amount of unearned Title IV aid due from the school is $3,138.75 (Box O). Since Title IV loans are returned before Title IV grants, and Unsubsidized Direct Loans are returned before Subsidized Direct Loans, the school returns $2,025.00 to the Direct Loan Program for crediting toward Baker’s Unsubsidized Direct Loan and $1,114.00 to the Direct Loan Program for crediting toward Baker’s Subsidized Direct Loan (Because the COD system will not accept requests for other than whole dollars [no cents] for the Direct Loan Program). The school also cancels the second disbursement of both of his Direct Loans.

The school must return any unearned funds within 45 days from the date of the institution’s determination that Baker withdrew.

Step 7: Initial Amount of Unearned Title IV Aid Due from Student

Box Q.

Subtract the amount of Title IV aid the school must return ($3,138.75) from Box O from the total amount of Title IV aid that is to be returned ($5,062.50) from Box K to find the initial amount of Title IV aid due from the student. $5,062.50 – $3,139.00 = $1,923.50.

Q. =

$1,923.50

The initial amount of Title IV aid due from the student, is $1,923.50.

Step 8: Repayment of the Student’s Loans

Box R.

Subtract the total loans the school must return ($3,138.75) from Box P from the net loans disbursed to the student ($4,725.00) from Box B to find the total of the loans the student must repay $4,725.00 – $3,139.00 = $1,586.00.

R. =

$1,586.00

Since the amount from Box Q ($1,923.50) is greater than the amount from Box R ($1,586.00), you proceed to Step 9.

Box S.

Subtract the amount of loans to be repaid by the student in Box R ($1,586.00) from the initial amount of unearned Title IV aid due from the student Box Q ($1,923.50) to find the initial amount of Title IV grants for the student to return $1,923.50 – $1,586.00 = $337.50.

S. =

$337.50

Box T.

Multiply the total Title IV grant aid disbursed and could have been disbursed for the period in Box F ($2,775.00) by 50% to find the amount of grant protection $2,775.00 X 50% = $1,387.50.

T. =

$1,387.50

Box U.

Subtract the amount of grant protection in Box T ($1,387.50) from the initial amount of Title IV grants for the student to return in Box S ($337.50) to find the Title IV grants for the student to return $337.50 – $1,387.50 = – $1,050.00.

U. =

– $1,050.00

Since the amount in Box U is less than or equal to zero, the student does not have to return any Title IV grant funds, and the calculation is complete.

Published: 03/28/2021