Chapter 3

Return of Title IV (R2T4) Funds Case Studies - Part 2

Case Studies 6 and 7:

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.

Case Study 8:

A student officially withdraws and is receiving Title IV grants at a school that uses a non-term program structure, measures academic progress in credit hours.

Case Study 6:

In this case study scenario, a student officially withdraws from a public residential school that utilizes a term-based modular course structure and measures progress in credit hours. The student has been disbursed Title IV grant funds.

Learning Objectives

Learn to complete Steps 1–10 of the Credit-Hour R2T4 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  • determine whether or not the student must be considered as withdrawn;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 if the student is due a post-withdrawal disbursement (PWD) of Title IV aid or if Title IV aid must be returned to the Department; and

  • determine the amount of any PWD due to the student or any amount that must be returned to the Department.

School Profile

Academic Year:

24 semester credit hours, 32 weeks, 2 semesters

Payment Period:

16 weeks/117 calendar days

Period Start Date:

August 22

Period End Date:

December 16

R2T4 Freeze Date
R2T4 Freeze Date:
R2T4 Freeze Date
September 10

Institutionally Scheduled Break:

Yes

Required to Take Attendance:

No

Method for Matching FSEOG:

Aggregate

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.

The school uses an R2T4 Freeze Date (RFD) to help calculate the number of days their students are scheduled to complete within modules.

Though it is not a school that is required to take attendance, the school 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

The student is an independent, third-year student and as of the school’s R2T4 Freeze Date is enrolled for 12 credits over four modules. In each module, a student is enrolled in one course that begins and ends on a fixed date. In the student’s case, each course is worth three credits.

Charges to the student’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)

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

Expense type
Tuition:
Housing:
Food:
Books & Supplies:
Personal Expenses:
Travel:
dollar amount
$2,400.00
$2,800.00
$1,600.00
$800.00
$800.00
$800.00

The student’s financial aid package included the following annual awards:

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

Discussion

On the first day of the period, August 22, the student received the following disbursements to their student account:

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

On October 17, the student comes to see you. Even though they fully attended his first two modules, they struggled with their coursework and earned Fs in both modules and is unsure if this is the correct career path for them. They need some time to think about their future and feels it is best if they withdraw 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 should ask the following five questions:

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

    In this student’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 scheduled course, 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 this student’s case, the answer to Question 2 is No; you go on 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 the answer is yes, this is not a withdrawal, but Pell recalculation may apply. If the answer is no, go to question 4.

    In this student’s case, the answer to Question 3 is No; you go on 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% 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 the answer is yes to either question, this is not a withdrawal, but Pell recalculations may apply. If the answer is no, go to question 5.

    In this student’s case, the answer to Question 4 is No; you go on to Question 5.

  5. Did the student confirm attendance in a later module in the payment/enrollment period (45-day rule for standard or nonstandard programs)?

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

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

Because the student does not meet any of the R2T4 withdrawal exemptions and did not provide any written confirmation of future attendance, the school must treat them as a withdrawn student.

Because the student failed to begin attendance in all of the classes on which their Pell Grant was based, before performing the required Return calculation, the school must perform a mandatory Pell recalculation for the student’s Pell based on their enrollment in just the two modules they began—six credits or half time. The student’s scheduled annual Pell award at 50% enrollment intensity is $2,775. Their revised first semester award is $1,388. The school must return $1,387 (the difference between the student’s initial Pell disbursement of $2,775 and their new award of $1,388), and include only their new award of $1,388 in the Title IV return calculation. The school returns the $1,387 through G6 and reduces the student’s Pell Grant in COD to $1,388.

In addition, since the student was receiving FSEOG, the school has to recalculate the student’s eligibility for Campus-Based funds, eliminating the costs attributable to the modules that they did not begin attending to see whether a reduction of the Campus-Based aid is necessary. Based on a revised COA for the fall semester and revised Pell Grant of $1,388, the student’s remaining first semester need is more than the student’s FSEOG award of $1,825.00. Therefore, the school does not need to reduce the student’s FSEOG award before performing the Title IV return calculation.

The school performed an R2T4 calculation using the student’s last date of attendance of October 14 as their withdrawal date (as per school policy); $1,388 as the amount of Pell Grant disbursed; and $1,825 as the amount of FSEOG funds disbursed. On October 24, the school returned the funds for which it was responsible to the appropriate programs, and made the appropriate adjustments in COD.

Solution

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

Step 1: Student’s Title IV Aid Information

Box A.

After recalculating and returning the Pell Grant funds for which the student 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

The school 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. the student’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 PWD is due, and we proceed to Box K.

PWD = N/A.

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

expense types
Tuition and fees:
Housing:
Food:
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.

The student had no loans, so the total loans the school must return = $0.00.

Box P
Box P =
Box P
$0.00

The student 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 $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 G6 system. The school must also reduce the student’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 the student 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:

In this case study scenario, a student (the same student from case study 6) who had previously officially withdrawn from a public residential school that utilizes a term-based modular course structure and measures progress in credit hours, returns within the same payment period and withdraws again. The student has been disbursed Title IV grant funds.

Learning Objectives

Learn to complete Steps 1–10 of the Credit-Hour R2T4 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 same 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 PWD of Title IV aid or if Title IV aid must be returned to the Department; and

  • determine the amount of any PWD due to the student or any amount that must be returned to the Department.

School Profile

Academic Year:

24 semester credit hours, 32 weeks, 2 semesters

Payment Period:

Payment Period Start Date:

Payment Period End Date:

R2T4 Freeze Date:

Institutionally Scheduled Break:

Required to Take Attendance:

Method for Matching FSEOG:

Period used in Return calculation:

1 semester/117 calendar days

August 22

December 16

September 10

Yes

No

Aggregate

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.

The school uses an R2T4 Freeze Date (RFD) to help calculate the number of days their students are scheduled to complete within modules.

Though it is not a school that is required to take attendance, it 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

The student was an independent third-year student enrolled for 12 credits offered over four modules as of the school’s R2T4 Freeze Date. In each module a student is enrolled in one course that begins and ends on a fixed date. In this student’s case, each course is worth three credits.

Charges to the student’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)

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

expense labels column
Tuition:
Housing:
Food:
Books & Supplies:
Personal Expenses:
Travel:
dollar amount column
$2,400.00
$2,800.00
$1,600.00
$800.00
$800.00
$800.00

The student’s financial aid package included the following annual awards:

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

Discussion

On the first day of module four, November 14, the student received the following disbursements to their student account:

award type column
Pell Grant:
FSEOG:
award dollar amount
$2,081.50
$218.50 (restoring the student's total to $1,825)

On November 11, the same student from Case Study 6, walks into your office and tells you that they would like to re-enter the program when the fourth module begins on November 14.

When the student 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 they 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 they were in at the time of the withdrawal and retains their original Title IV eligibility for that payment period, provided the student’s enrollment status/intensity continues to support the same amount of those funds. To do this, the school must:

  • recalculate the student’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 the student's enrollment status/intensity;

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

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

When the student returns in module four, the three credits for that module are added to the six credits that they completed previously. Nine credits at the school are the minimum number required for three-quarter-time enrollment status or 75% enrollment intensity for Pell Grant purposes. Therefore, the school must recalculate the student’s eligibility for Title IV assistance as a three-quarter time student. The student’s scheduled annual Pell award with a 75% enrollment intensity is $4,163.00, and his one-semester award is $2,081.50.

After recalculating the student’s eligibility from full time to half time when they withdrew previously, the school returned $1,387.00 (the difference between the student’s initial Pell disbursement of $2,775.00 and their 50% enrollment intensity award of $1,388.00). The school then included only the student’s 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 the student’s Pell award in COD to $0.00. When the student returns, the school must once again adjust their award in COD (this time to his 75% enrollment intensity award of $2,081.50) and draw down and disburse $2,081.50 to their account.

In addition, the school has to recalculate the student’s eligibility for FSEOG, adding the costs attributable to the additional module that they have begun attending, to see whether a modification of the student’s FSEOG is necessary. Based on a revised COA for the fall semester and revised Pell Grant of $2,081.50, the student’s remaining first-semester need is greater than their 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 the student.

When the financial aid administrator reviews the results of the previous Title IV return calculation, they find that the student had not been required to return any Title IV aid; therefore, there are no student overpayments to cancel.

After class on December 5, the student once again comes to see you and tells you they have 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 should review the following five questions:

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

    In this student’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 scheduled course, 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 this student’s case, the answer to Question 2 is No; you go on 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 the answer is yes, this is not a withdrawal, but Pell recalculation may apply. If the answer is no, go to question 3.

    In this student’s case, the answer to Question 3 is No; you go on 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% 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 the answer is yes to either question, this is not a withdrawal, but Pell recalculations may apply. If the answer is no, go to question 5.

      In this student’s case, the answer to Question 4 is No; you go on to Question 5.

  5. Did the student confirm attendance in a later module in the payment/enrollment period (45-day rule for standard or nonstandard programs)?

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

    In this student’s case, the answer is No; and you must treat them as a withdrawal.

The student began attendance in all of the classes on which their Pell Grant was based (modules 1,2, and 4). Therefore, the school did not need to perform a mandatory Pell Grant recalculation. In addition, since the student began attendance in all of the classes on which FSEOG was based, the school did not have to recalculate their FSEOG eligibility.

Solution

Per school policy, the student’s withdrawal date is his last date 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 the student had begun all modules (classes) on which their Pell and FSEOG 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 that 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 that 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, the school has a 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 the student was enrolled in module three as of the school’s R2T4 Freeze Date (September 10), module three is considered to have been used to determine the amount of the student’s eligibility for Title IV aid, and therefore, the days from module three are also 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 R2T4 calculation, we know that the student completed 54 days in modules one and two. The student 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 if the student was due a PWD.

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 that 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:

In this case study scenario, a student officially withdraws from a proprietary school that utilizes a non-term program structure and measures progress in credit hours. The student has been disbursed Title IV grant funds, Federal Work Study (FWS), and Direct Loan funds and is not scheduled to return within 60 days.

Learning Objectives

Learn to complete Steps 1–10 of the Credit-Hour R2T4 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 if the student is due a PWD of Title IV aid or if Title IV aid must be returned to the Department; and

  • determine the amounts of any PWD due to the student or returned to the Department.

School Profile

Academic Year:

24 credits, 32 weeks

Payment Period:

12 credit hours (4 courses each 4 weeks long) 16 weeks

Period Start Date:

Period End Date:

Institutionally Scheduled Break:

Required to Take Attendance:

Method for Matching FSEOG:

Period Used in Return Calculation:

August 1

November 18

No

No

Aggregate

Payment Period

Course structure within payment period includes:

Start

Start date column
August 1
August 29
September 26
October 26

End

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

The student is a dependent, fourth-year student enrolled in four courses for 12 credits throughout the payment period. In each payment period, a student enrolls in four courses that begin and end on fixed dates. In this student’s case, each course is worth three credits.

Charges to the student’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)

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

Expense label column
Tuition:
Housing:
Food:
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

The student’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

Discussion

On the first day of the period, August 1, the student received the following disbursements to their student account:

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, the student comes to see you and tells you thatthey intend to drop courses two and three, and return for the original fourth course on October 26. On August 26, the student completes their first course and withdraws.

Under 34 CFR 668.22(l)(6), a program is ‘‘offered in modules’’ 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. Based upon the Department’s definition of a program offered in modules established in the September 2, 2020 final regulations, the school’s non-term program is NOT considered a program offered in modules. Therefore, none of the R2T4 module requirements apply, including the withdrawal exemptions associated with modules.

Note: 34 CFR 34 668.22(a)(2)(i)(D) provides that a student in a non-term or subscription-based program is considered to have withdrawn for Title IV purposes 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. 34 CFR 668.22(a)(2)(ii)(A)(5) provides that, for a non-term program, a student is not considered to have withdrawn if the school obtains written confirmation from the student at the time that would have been a withdrawal of the date that they will resume attendance, and that date is no later than 60 calendar days after the student ceased attendance. The course in which this student will be returning does not start until October 26. That is 61 days from August 26, the end of the first course. Therefore, in this student’s case, since they are unable to provide written confirmation that they will return within 60 days after ceasing attendance, the student must be treated as a withdrawal.

Because the student failed to begin attendance in all of the classes on which their Title IV aid was based, before performing the required Return calculation the school must recalculate the student’s Title IV eligibility based on their enrollment in just the one course they 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 100% enrollment intensity. Therefore, a school does not have to recalculate a Pell Grant when a student attending a non-term program or clock-hour program withdraws.

The school does have to recalculate the student’s eligibility for Campus-Based aid (FSEOG and FWS), eliminating the costs attributable to the courses that they 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 the student’s enrollment in the first course was $2,600.00. The loan funds that the student had already received (and for which their eligibility does not have to be recalculated—$2,700.00) plus their Pell Grant ($2,775.00), plus the $500.00 in FWS the student has earned to date equal $5,975.00. Since $5,975.00 exceeds the revised COA of $2,600.00, the financial aid administrator determined that the student was not eligible for any FSEOG funds, so the school had to reduce the student’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 changes their 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 costs associated with any classes the student failed to begin in the COA. Moreover, when a student enrolled in a clock-hour or non-term 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 60 days in the student’s COA.

The school performed an R2T4 calculation using the student’s last date 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, the school returned the funds for which it was responsible to the appropriate programs.

Solution

The student’s withdrawal date is their last date of attendance at an academically related activity as determined from the school’s attendance records, August 26.

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 that 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 that 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, the student’s withdrawal date is August 26, the day they dropped their second and third courses and notified the school that they would not be returning until the start of their fourth course (61 days after ceasing attendance).

  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 that 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 PWD is due, and we proceed to Box K.

PWD = N/A.

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

charge labels
Tuition and fees:
Housing:
Food:
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 the student 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 the student 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.

Last Modified: 05/15/2024 • Published: 03/28/2021