1. National Association of Student Financial Aid Administrators Presents … © NASFAA 2011 Return of Title IV Funds

2. Slide 12-2 © NASFAA 2011 Program Integrity Rules Published Oct 2010 Taking attendance Calculating R2T4 Modular enrollments

3. Slide 12-3 © NASFAA 2011 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

4. Slide 12-4 © NASFAA 2011 Return of Title IV Funds Requirements Amount of 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

5. Slide 12-5 © NASFAA 2011 When Return of Title IV Funds Requirements Apply Requirements apply to a Title IV grant or loan recipient, as defined in regulation, who withdraws or leaves school before completing the payment period or period of enrollment

6. Slide 12-6 © NASFAA 2011 Required to take Attendance Outside agency School requires it If you have it……. must use it………….

7. Slide 12-7 © NASFAA 2011 What about Census Date If school is required to take attendance only for a single date This is not considered to be ‘required to take attendance’

8. Slide 12-8 © NASFAA 2011 Schools Not Required to Take Attendance For schools not required to take attendance, how the school establishes a student’s withdrawal date depends on whether the student: Officially withdrew; or Dropped out without notifying school (i.e., unofficially withdrew)

9. Slide 12-9 © NASFAA 2011 Last Academic Activity If not required to take attendance, you can use the student’s last date of attendance at an ‘academically related activity’ as the withdrawal date As of 7/1/11 changed definition of activity

10. Slide 12-10 © NASFAA 2011 Academic Activity Examples Submitting academic assignment Taking an exam Attend study group Participate in an online discussion about academic matters Initiating contact with a faculty member to ask question about their course

11. Slide 12-11 © NASFAA 2011 Activities you can’t use!!! Living in institutional housing Participating in the institution’s meal plan Logging into an online class without active participation Participating in academic counseling

12. Slide 12-12 © NASFAA 2011 Modules( aka mini sessions) If a student officially drops courses in a later module while still attending current module, the student would not be considered as withdrawn for not attending the later module because the student is no longer scheduled to attend. Recalculation may be required on status

13. Slide 12-13 © NASFAA 2011 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

14. Slide 12-14 © NASFAA 2011 Example: Rescission of Withdrawal September 20: Alan notifies the school he is withdrawing September 27: Alan rescinds the withdrawal and participates in a special tutoring session October 1: Alan fails second exam and again notifies the school he is withdrawing

15. Slide 12-15 © NASFAA 2011 Example: Rescission of Withdrawal Based on actions taken by Alan, school may use as the withdrawal date: October 1, based on documentation Alan took second exam September 27, if Alan withdrew before exam and school can document attendance at tutoring session School must use September 20, if school chooses not to use, or has no documentation of, last date of attendance in an academically-related activity

16. Slide 12-16 © NASFAA 2011 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 Student who completed more than 60% of period has earned 100% of his or her Title IV aid for the period

17. Slide 12-17 © NASFAA 2011 Example—Daisy: Term-Based Credit-Hour Program Semester: 1/3/11 - 5/6/11 Federal holidays, no classes scheduled: 1/17/11 and 2/21/11 Spring break, no classes scheduled: 3/5/11 - 3/13/11; classes resume 3/14/11

18. Slide 12-18 © NASFAA 2011 Example—Daisy: Term-Based Credit-Hour Program Official withdrawal: 3/25/11 Attended 73 days of 115 days (include holidays; exclude spring break) Percentage completed: 73  115 = 63.5%

19. Slide 12-19 © NASFAA 2011 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 © NASFAA 2011 Earned Aid Total aid X % completed = Earned aid

21. Slide 12-21 © NASFAA 2011 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 © NASFAA 2011 Example: Post-Withdrawal Disbursement $1,250 post-withdrawal disbursement Undisbursed aid = $1,000 Federal Pell Grant, $750 FSEOG, and $2,000 Federal Perkins Loan Post-withdrawal disbursement must be made from grant funds first

23. Slide 12-23 © NASFAA 2011 Example: Post-Withdrawal Disbursement $1,250 post-withdrawal disbursement Undisbursed aid = $1,000 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 © NASFAA 2011 Post-Withdrawal Disbursements If outstanding institutional charges: –May credit post-withdrawal disbursement of grant funds –Must notify borrower and obtain confirmation to credit post-withdrawal disbursement of loan funds Any post-withdrawal disbursement to institutional charges must comply with Title IV cash management rules

25. Slide 12-25 © NASFAA 2011 Important Number of days 30 days– determined that they withdrew 45 days - return funds to feds by than 30 days- provide written notification concerning post withdrawal disbursement

26. Slide 12-26 © NASFAA 2011 Resources Federal Financial Handbook –Withdrawals and Return of Title IV Funds http://www.ifap.ed.gov/qahome/qaassessm ents/returntivfunds.htmlhttp://www.ifap.ed.gov/qahome/qaassessm ents/returntivfunds.html Return of Title IV Funds on the Web

27. Slide 12-27 © NASFAA 2011 Post-Withdrawal Disbursements If no outstanding institutional charges or disbursement greater than outstanding charges: School must directly disburse any amount of grant post-withdrawal disbursement School must notify borrower and obtain confirmation to disburse the loan funds

28. Slide 12-28 © NASFAA 2011