Return of Title IV funds Sandra Cronin Senior Associate Director Point Park University

Agenda 1.Brief overview of Return of Title IV funds 2.Case study example from Federal Student Aid Handbook 3.Aid that Could Have Been Disbursed 4.Verification Completed (or Not) 5.Modules 6.Attendance

If time permits… Discussion of “best practices” Did you ever think about the order of returning of funds? Deceased students Institutional charges

What is R2T4 anyway? R2T4 is the acronym used by financial aid professionals for the Return of Title IV funds process. The Return of Title IV funds calculation is completed when a Federal Title IV aid recipient either – A) officially withdraws; – B) unofficially withdraws; – C) stops attending class per the attendance policy

Return of Title IV Funds is COMPLEX! I t has its own volume in the Federal Student Aid Handbook (Volume 5) 124 pages of material about Return of Title IV funds plus… 77 pages of case studies

A regulation that makes sense! Most schools give students 100% of their aid for the entire semester up front. When a student withdraws, the institution calculates how long the student was in class and the percentage of time for “earned” aid. That percentage is then applied to the amount of funds awarded, and the difference is then returned to the appropriate program.

Worksheets/Software available Return of Title IV funds on the web: aAccessServlet aAccessServlet Federal Student Aid Handbook, Volume 5, Chapter 1 Financial Aid Management system internal

Agenda 1.Brief overview of Return of Title IV funds 2.Case study example from Federal Student Aid Handbook 3.Aid that Could Have Been Disbursed 4.Verification Completed (or Not) 5.Modules 6.Attendance

Case Study Let’s discuss a case study from the Student Financial Aid Handbook. Handout provided to participants; Federal Student Aid Handbook – Case Study #2, Bob Ellison

Agenda 1.Brief overview of Return of Title IV funds 2.Case study example from Federal Student Aid Handbook 3.Aid that Could Have Been Disbursed 4.Verification Completed (or Not) 5.Modules 6.Attendance

Aid That Could Have Been Disbursed Aid that the student was awarded that the student established eligibility to receive and met all other conditions for a late disbursement Inadvertent overpayments (aid disbursed after the student ceased attendance before the school was aware of the intent to withdraw).

Aid That Could Have Been Disbursed… Net amount of loan proceeds You can include loan proceeds if the student completes the MPN after withdrawing if the MPN is completed before the R2T4 calculation is completed.

More information about loans… You can include loan funds that could never be disbursed because of statutory and/or regulatory requirements: – A second or subsequent Direct Loan Disbursement – Funds that are subject to the 30 day delay These funds can be included in the calculation, but not offered as a post-withdrawal disbursement.

Aid that Could Have Been Disbursed… Institutional share of FSEOG only if using the fund-specific matching method – More information about the different types of matching are in the Federal Student Aid Handbook, Volume 6, Chapter 1.

Agenda 1.Brief overview of Return of Title IV funds 2.Case study example from Federal Student Aid Handbook 3.Aid that Could Have Been Disbursed 4.Verification Completed (or Not) 5.Modules 6.Attendance

Verification If the verification has been completed before the student withdraws, you can proceed with the calculation. If the verification has NOT been completed… – The school must complete the Return of Title IV funds calculation only on Title IV funds not subject to verification (Direct Unsubsidized Loan, Direct PLUS, TEACH Grant).

Verification NOT complete The school must return any unearned funds, including interim disbursements of the Federal Pell Grant, IASGA, FSEOG, or Federal Perkins Loan.

…and then the student completes verification If the student does then provide the verification submission deadline, then… – The school completes the verification; – Adjusts the award if necessary; – Perform a new Return of Title IV funds calculation. The new calculation can only include funds the meet the late disbursement regulations under section (g)(2).

Verification complete after initial calculation If the student is eligible for a post- withdrawal disbursement of a loan, you must send the required notifications requesting confirmation of the post- withdrawal disbursement

Agenda 1.Brief overview of Return of Title IV funds 2.Case study example from Federal Student Aid Handbook 3.Aid that Could Have Been Disbursed 4.Verification Completed (or Not) 5.Modules 6.Attendance

Modules What is a modular program? – “An academic program in which all the courses do not span the length of the payment period or period of enrollment.” – NASFAA University R2T4 Online Course Glossary.

Example A student is registered for 12 credits over four mini-sessions within a larger payment period. – 3 credits August 22-September 16 – 3 credits September 19-October 14 – 3 credits October 17-November 11 – 3 credits November 14-November 16 The student withdraws from the first 6 credits in mid-October and drops the second 6 credits at the same time. (See case study #6 in FSA handbook)

How to calculate the R2T4 The third and fourth modules are considered a drop; recalculate the student’s eligibility of funds for the first 6 credits. Then, perform the Return of Title IV funds calculation on the first 6 credits of aid and charges.

…and then the student decides to return A student is registered for 12 credits over four mini-sessions within a larger payment period. – 3 credits August 22-September 16 – 3 credits September 19-October 14 – 3 credits October 17-November 11 – 3 credits November 14-November 16 The student withdrew in mid-October, but decides to return for the last module starting November 14 th. (Case study #7, FSA Handbook).

Modular programs – student returns First, recalculate the student’s eligibility for funds for the modules he attended (1 & 2) and the module he intends to complete (4). Disburse any funds the student is now eligible to receive based on his new enrollment status that had not yet been disbursed at the time of the withdrawal. Cancel any Title IV overpayments if applicable.

What if…the student does not officially withdraw from a modular program? A student is registered for 12 credits over two mini-sessions within a larger payment period. – 6 credits from late August until mid-October – 6 credits from mid-October to mid-December. The student attends the first module, but fails to successfully complete any classes.

Confirm Attendance If the student stopped attending one module, you must have the student confirm attendance in the next modular session in writing. Return of Title IV funds is not required for the first module if the student confirms intention to attend next module.

Confirm Attendance If the student does not confirm attendance in the next module, then calculate the Return of Title IV funds for the first module using eligibility for funds and charges only for the first module.

Clock Hour or Non-term Credit Hour Re-entry If a student re-enters the same program within 180 calendar days of his or her withdrawal, the student is considered reinstated. – The student has not withdrawn; – The student is in the same payment period at the time of withdrawal

Re-entry (clock hour or non-term credit hour) Cancel overpayments assessed at time of withdrawal; Undo the previous Return of Title IV calculation; Restore and disburse the aid the student is eligible to receive.

Agenda 1.Brief overview of Return of Title IV funds 2.Case study example from Federal Student Aid Handbook 3.Aid that Could Have Been Disbursed 4.Verification Completed (or Not) 5.Modules 6.Attendance

To take attendance or not to take attendance…. If required by an outside agency, such as an accrediting agency, then the school may be required to take attendance. School can choose to take attendance. The regulations do not specify the types of attendance records the school must keep nor the procedure for routinely monitoring the attendance records.

Not Required to take Attendance Official withdrawal – Student starts withdrawal process – Officially notifies the school of the intent to withdraw; School must designate at least one campus office for this purpose. – Student may rescind the withdrawal notification

Unofficial Withdrawals School has the option of using the midpoint of the payment period of documenting the last day of attendance. If a student fails to earn a passing grade in any of their classes, this may be considered an unofficial withdrawal (depending on the grading system)

Point Park’s Transition Prior to Fall 2014, attendance was not required. No last date of attendance was required to be entered for failing grades Unofficial withdrawals (students not successfully completing any courses) were calculated using the midpoint of the semester.

Fall 2014 Announcement made that Point Park would start requiring faculty to take attendance. Worked with Registrar and IT to develop a report for monitoring non-attendance. Updated our policy to complete Return of Title IV calculation after a period of non- attendance in all classes.

NASFAA Online Class NASFAA offers a variety of online classes for financial aid professionals to earn recognized credentials. More information available at: I really learned a lot by taking the class – there is a lot of interaction with other professionals.

If time permits… Discussion of “best practices” Did you ever think about the order of returning of funds? Deceased students Institutional charges

THANK YOU! Sandra Cronin