1. National Association of Student Financial Aid Administrators Presents … © 2015 NASFAA Return of Title IV Funds Module 12

2. Slide 12-2 © 2015 NASFAA Return of Title IV Funds Requirements Amount of earned Title IV aid is proportionate to portion of period completed at the time student withdrew Unearned Title IV aid must be returned Undisbursed earned Title IV aid must be disbursed or offered

3. Slide 12-3 © 2015 NASFAA Return of Title IV Funds Requirements Amount of unearned Title IV aid to be returned is independent of institutional charges assessed under school’s refund policy Title IV regulations do not govern school’s refund policy

4. Slide 12-4 © 2015 NASFAA When Return of Title IV Funds Requirements Apply A withdrawal occurs when a Title IV recipient withdraws or ceases attendance before the end of a payment period or period of enrollment

5. Slide 12-5 © 2015 NASFAA Example: Programs Offered in Modules Dennis: Enrolled in 15-week semester Term includes three, five-week modules; run consecutively Enrolled in two courses during 15-week semester and one course in 1 st and 2 nd modules Withdrew from all classes on Day 30 of 1st module Provided school with written confirmation

6. Slide 12-6 © 2015 NASFAA Example: Programs Offered in Modules Questions to ask: 1.After beginning attendance, did student stop attending in a course he was scheduled to attend? 2.When student stopped attending, was he still attending any other courses? 3.Did student confirm attendance in writing for enrollment in a course in a module later in the payment period or period of enrollment?

7. Slide 12-7 © 2015 NASFAA Schools Not Required to Take Attendance How the school establishes a student’s withdrawal date depends on whether the student is an: Official withdrawal; or Unofficial withdrawal (i.e. dropped out without notifying school)

8. Slide 12-8 © 2015 NASFAA Rescinding Official Withdrawal Notice A student may rescind his or her withdrawal: Must be in writing Student must declare he or she will finish payment period or period of enrollment

9. Slide 12-9 © 2015 NASFAA Example: Rescission of Withdrawal September 18: Alan notifies the school he is withdrawing September 25: Alan participates in a special tutoring session September 30: Alan fails second exam and again notifies the school he is withdrawing

10. Slide 12-10 © 2015 NASFAA Example: Rescission of Withdrawal Based on actions taken by Alan, school may use as the withdrawal date: September 30, based on documentation Alan took second exam September 25, if Alan withdrew before exam and school can document attendance at tutoring session School must use September 18, if school chooses not to use, or has no documentation of, last date of attendance in an academically-related activity

11. Slide 12-11 © 2015 NASFAA Example: Unofficial Withdrawal Payment period contains two 8-week credit- hour modules with two days between modules Bethany enrolls in both modules and unofficially withdraws after completing the first module of the payment period What is her withdrawal date?

12. Slide 12-12 © 2015 NASFAA Example: Unofficial Withdrawal Calculate the total number of days Bethany was scheduled to attend during the payment period including any scheduled break less than 5 consecutive days 8 weeks x 7 days x 2 modules = 112 days 112 days + 2-day break between modules = 114 days Calculate midpoint of the payment period, which is her withdrawal date 114 days ÷ 2 = 57

13. Slide 12-13 © 2015 NASFAA Leave of Absence Leave of absence (LOA) refers to a temporary interruption in a student’s studies Does not include: –Nonattendance during a scheduled break –Situations addressed by course incompletes

14. Slide 12-14 © 2015 NASFAA Example: Re-Entry Within 180 Days Selma begins attendance in a semester-based, credit-hour program Each semester consists of three 5-week modules Selma was scheduled to attend Modules 1 and 2, but fails to begin attendance in Module 2 and does not confirm future attendance School performs a return of Title IV funds calculation; returns portion of Selma’s previously disbursed monies to Title IV aid programs

15. Slide 12-15 © 2015 NASFAA Example: Re-Entry Within 180 Days Selma returns within 180 days and enrolls in Module 3 School must: –Undo return of Title IV funds calculation –Restore aid for which Selma was eligible before ceasing attendance

16. Slide 12-16 © 2015 NASFAA Return of Title IV Funds Formula— Step 1 Determine percentage of earned aid: Based on percentage of period completed Calculation of percentage completed is the only difference between credit-hour and clock-hour programs

17. Slide 12-17 © 2015 NASFAA Example—Daisy: Term-Based Credit-Hour Program Semester: 1/4/16 to 5/2/16 Federal holidays, no classes scheduled: 1/18/16 and 2/15/16 Spring break, no classes scheduled: 2/27/16 to 3/6/16; classes resume 3/7/16

18. Slide 12-18 © 2015 NASFAA Example—Daisy: Term-Based Credit-Hour Program Official withdrawal: 3/21/16 Attended 69 days of 111 days (include holidays; exclude spring break) Percentage completed: 69  111 = 62.2%

19. Slide 12-19 © 2015 NASFAA Example: Nonterm Credit-Hour Program 24-credit-hour, 30-week nonterm program Student expected to complete 12 credit hours each payment period Student originally expected to complete each payment period in 15 weeks (105 days) Student withdraws on day 30 after completing 2 credit hours At current pace (2 credit hours every 30 days), project 150 additional days needed to complete payment period; total 180-day payment period

20. Slide 12-20 © 2015 NASFAA Earned Aid Total aid X % completed = Earned aid

21. Slide 12-21 © 2015 NASFAA Example: Prorating Institutional Charges School charges $6,000 up front for entire program with 2 payment periods $4,000 in Title IV funds applied to student’s account for the first payment period Student withdraws during first payment period Student’s prorated charges: $6,000 ÷ 2 = $3,000 Because applied aid is larger than prorated charges, school must use applied aid as amount of institutional charges to calculate school’s share of earned aid

22. Slide 12-22 © 2015 NASFAA Example: Post-Withdrawal Disbursement $1,290 post-withdrawal disbursement Undisbursed aid = –$1,040 Federal Pell Grant, –$750 Federal Supplemental Educational Opportunity Grant (FSEOG), and –$2,000 Federal Perkins Loan Post-withdrawal disbursement must be made from grant funds

23. Slide 12-23 © 2015 NASFAA Example: Post-Withdrawal Disbursement $1,290 post-withdrawal disbursement Undisbursed aid = –$1,040 Federal Pell Grant, –$750 FSEOG, and –$2,000 Federal Perkins Loan Suppose student already received $500 Direct Loan School cannot use $500 remaining grant funds to replace previously disbursed loan proceeds

24. Slide 12-24 © 2015 NASFAA Post-Withdrawal Disbursements School must directly disburse to the student any amount of a post-withdrawal disbursement of grant funds not credited to the student’s account

25. Slide 12-25 © 2015 NASFAA