1. RAWR……or R2T4 Crystal Bruntz Director of Financial Aid Avila University

2. Return of Title IV Funds  IT’S COMPLEX!!!  Has its own volume in the Federal Student Aid Handbook (Volume 5)  124 pages of material  Plus 77 pages of case studies

3. Return of Title IV Funds  An institution is required to determine earned and unearned portion of Title IV aid when a student ceases enrollment prior to the planned completion date  Post-withdrawal disbursement – Amount paid to student as earned Title IV funds after R2T4 calculation is completed  Unearned funds – Funds that must be returned to appropriate Title IV program

4. Return of Title IV Funds  Title IV recipient:  Student who actually received a disbursement of Title IV grant or loans funds, or who met the qualifications for a late disbursement of Title IV funds [R2T4 does not apply to Federal Work-Study (FWS)]  If student never began attendance, R2T4 does not apply (all Title IV aid must be cancelled)

5. Overview of R2T4 Process Determine student’s withdrawal date Calculate percentage of payment period or period of enrollment completed Determine amount earned by applying percent completed to total Title IV aid disbursed and that could have been disbursed Decide if earned funds are due to the student through a Post-Withdrawal Disbursement; obtain permissions and credit as allowed Decide if unearned funds are due to Title IV programs, and whether they are due from the student or the school

6. General Principles  Required to take attendance – Can be required by an outside entity (such as an accreditor or state agency), or the institution itself, or a requirement that can be met only by taking attendance  Must use official attendance records  Could apply to a subset of students, or for a certain period of time  Not required to take attendance

7. General Principles  Withdrawal date – The withdrawal date is used to calculate the amount of earned and unearned funds  Determination of the withdrawal date is driven by whether the institution is required to take attendance  School should use best information available to determine withdrawal date and document it.

8. General Principles  Date of determination  Official withdrawal – Student begins school’s withdrawal process or provides notification he or she will withdraw, or both o Date of determination is the earlier of the two dates  Unofficial withdrawal – Date of determination is the date the school becomes aware the student has ceased attendance  At schools required to take attendance – Date of determination should be no more than 14 days after the last date of attendance

9. General Principles  Institutional charges:  Includes tuition and fees (required of all students in program)  Room and board, if contracted with the school  Books, supplies, materials, and equipment, if the student cannot reasonably get them anywhere besides from the school

10. General Principles  Payment period versus period of enrollment: The program type determines which measure is used for the calculation:  For students who withdraw from a trimester, semester, or quarter program – use payment period  For students who withdraw from a nonstandard term- based or non term-based program – School can choose to use either payment period or period of enrollment

11. Scheduled Breaks  At least five (5) scheduled days  How to determine the length of a scheduled break:  Determine the last day that class is held before a scheduled break – the next day is the first day of the scheduled break.  The last day of the scheduled break is the day before the next class is held.

12. Modular Programs  Modules are courses in a student’s program that do not span the entire length of the payment period or period of enrollment  Example: School has 14-week summer term, during which students can enroll in any or all of the following sessions: o Two 5-week sessions offered one after the other o A single 14-week session

13. Modular Programs  Examples:  Two 5-week sessions offered one after the other  A single 14-week session  A student enrolled in one or both 5-week sessions is considered to be enrolled in a program offered in modules  A student enrolled in one 5-week session and the 14-week session is considered to be enrolled in a program offered in modules  A student enrolled in only the 14-week session would not be considered enrolled in a program offered in modules

14. Modular Programs  If student begins one or more modules, but does not begin next module he is scheduled to attend and does not provide written confirmation at time of withdrawal stating his planned attendance in a module beginning later in same payment period or period of enrollment, he is considered to have withdrawn because he did not complete all the days he was scheduled to attend  Under current regulations, completion of one course in one module in a term-based credit-hour program no longer means student has not withdrawn

15. Determining Withdrawal from a Modular Program Determine withdrawal by asking three questions: 1.After beginning attendance in the payment period or period of enrollment, did the student cease attendance or fail to begin attendance in a course he or she was scheduled to attend? - If no, this is not a withdrawal - If yes, proceed to question 2

16. Determining Withdrawal from a Modular Program 2.When the student ceased attendance or failed to begin attendance in a course he or she was scheduled to attend, was the student still attending other courses? - If yes, this is not a withdrawal. Recalculate aid per applicable program regulations and school policies - If no, proceed to question 3

17. Determining Withdrawal from a Modular Program 3.Did the student confirm in writing his or her intent to attend a course in the module beginning later in the term? - If yes, this is not a withdrawal. Recalculate aid per applicable program regulations and school policies - If no, R2T4 regulations apply

18. Modular Programs 3.Did the student confirm in writing his or her intent to attend a course in the module beginning later in the term? - If yes, this is not a withdrawal. Recalculate aid per applicable program regulations and school policies - If no, R2T4 regulations apply

19. Written Confirmation of Future Attendance  ED realized that modular programs often lend themselves to flexible and changing enrollments, so it provided a way for schools to be excused from doing R2T4s for class schedule changes  This is referred to as the intent to return notification

20. Written Confirmation of Future Attendance  Student must confirm intent to attend module later in same period  Must be a positive confirmation from the student  Can be electronic  Cannot assume student will come back for classes already scheduled  New enrollment in classes later in the module show intent to return

21. Written Confirmation of Future Attendance  Timing:  Must be received close to date student ceased attendance  Must be received before time period elapses that school must take R2T4-related action required by regulation

22. Student Returns to School During Period  If student returns in same payment period or period of enrollment before R2T4 process is completed, no requirement to complete R2T4 process  If student returns to school within same payment period or period of enrollment, or within 180 calendar days for clock- hour or nonterm credit hour programs after R2T4 has been completed, school must “undo” R2T4 calculation

23. Student Says They Will Return, But…  If the R2T4 calculation is not completed because a student says she will return later in the period, but the student does not return:  The withdrawal date is the last date of attendance, the midpoint, or the last date of attendance in an academically-related activity (depending on whether school is required to take attendance)

24. Return of Title IV Funds  Earned vs. Unearned aid  60% point  Student completes more than 60% of the PP or POE, student earned 100% of aid.  Does not dictate institutional refund policy Refund policy does not affect the amount of Title IV Aid the student has earned.

25. Determining Percentage of Days Completed For credit-hour programs: Days attended Days in period = % completed

26. Determining Percentage of Days Completed  However, if the student dropped the classes in the 2nd and 3rd modules before ceasing attendance in the 1st module, the number of days in the period would be only the days in the first module  Scheduled breaks of more than 5 consecutive days should be excluded when calculating percentage completed

27. Audit Findings (NASFAA)  Calculation Errors  Late R2T4 calculation and/or return of unearned Title IV funds  Incorrect number of days  Ineligible funds used as aid that “could have been disbursed”  Improper treatment of grant overpayments  Incorrect withdrawal date

28. Audit Findings (NASFAA)  Mathematical and/or rounding errors  School’s policies and procedures not followed  Returns not made within allowable time frame (45 days)  Inadequate system in place to identify and track official and unofficial withdrawals  No system in place to track number of days remaining to return funds

29. Questions?

30. THANK YOU!!! Crystal Bruntz Director of Financial Aid Avila University Crystal.bruntz@avila.edu