Return to Title IV: Are Your Withdrawals Passing the Compliance

Test?

Presented By: Vanessa M. Fulton

Georgia Institute of Technology

Topics

• Regulatory Info and Compliance • R2T4 Processing• Unofficial Withdrawals • Faculty Roles • Post-Withdrawal Disbursements • R2T4 for HOPE/Zell/Accel• Q & A

What is R2T4???

• Schools are required to determine the earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance or, in the case of a clock-hour program, was scheduled to be in attendance up until the 60% point.

• After 60%, student is considered to have earned 100% of Title IV aid.

• If school has disbursed less aid than the student has earned, a post-withdrawal disbursement will be calculated.

Example 1

Sally withdrew from 2 out of 4 of her classes. She contacts her advisor and asks if she will owe money based on Return to Title IV regulations. -Does she?

Answer 1

Nope!–Why?

• Only applies to students whom completely withdrawal from school.

Regulatory Information

• If a school determines that a student has withdrawn, the student is no longer considered to be enrolled and in attendance. Therefore, the student is no longer eligible for an in-school status or in-school deferment, and the school must report the student as withdrawn in NSLDS Enrollment Reporting.

Compliance

Program Reviews/Audit Findings

• Late Returns (outside of 45 days)• Errors in calculating Institutional

Charges• R2T4 not completed when needed• Not performing unofficial

withdrawals

Institutional Charges

• Tuition• Mandatory Fees• Meal Plan• Housing• Required Course Material• Testing fees (if it belongs to a

course)

Not Considered Institutional Charges

Examples:

• Parking Fines• Parking Permits• Health Insurance • Returned Check fees

Review R2T4 before Audits!

• Sample populations of your R2T4 per term to review for accuracy.

• Compare with Registrar rosters of withdrawn students to make sure none were missed.

• Communication and review of Bursar published dates: do they match?

• Complete FSA Assessments for R2T4.

FSA Assessment

Activities 1-3

R2T4 Processing

• Process in Banner • Process in FSA• Hand Calculations• Blank Worksheets located in Volume

5 of the 1415 Handbook via IFAP

FAA Access to CPS Online

Click Here

R2T4 Worksheet

Page 1 of R2T4 Form

Order of returns

• Unsubsidized Stafford Loan• Subsidized Stafford Loan• Perkins Loan• Parent Loan for Undergraduate

Students (PLUS)/Graduate PLUS• Pell Grant• Federal Supplemental Educational

Opportunity Grant (SEOG)

Unofficial Withdrawals

• No later than 30 days after end of: • The payment period (or period of

enrollment) • The academic year, or • The student’s educational program • If required to take attendance,

determine no later than 14 days after student’s LDA.

Unofficial Withdrawals, cont’d

• Unless you can document that a student completed the period, if a student fails to earn a passing grade in at least one course offered over the entire period, you must assume that student has unofficially withdrawn!

• Note: Documentation cannot come from the student, it must come from the professor or an appropriate person that would be designated to confirm attendance.

Example 2

Eric withdrew from 3 courses with a grade of W, he then fails his last course. Is this an unofficial withdrawal?

Answer 2

It Depends! – Why?

• Because we do not know at what point of the term the “F” was given, and considering the other grades are recorded as ‘W’, we must contact the professor to determine if the student attended past the 60% mark. – If yes, then he is not an unofficial withdrawal. – If no, then he must be processed for an

unofficial withdrawal.

Last Date of Attendance

A school is required to take attendance if: • The school is required to take attendance

by an outside entity; • The school itself has a requirement to

take attendance; • The school, or an outside entity, has a

requirement that can only be met by taking attendance.

Not Required to take Attendance

Schools not required to take attendance: • If a student provides official notification, then the

withdrawal date is the date the student begins the official withdrawal process or provides notification of intent to withdraw.

• Please note that a school not required to take attendance may always use a last date of attendance at an academically related activity as the student’s withdrawal date – the school must be able to document the student’s attendance at that activity.

Academically Related Activity

• Examples of academically related activities are:• Examinations or quizzes• Tutorials• Computer-assisted instruction• Academic advising or counseling• Academic conferences• Completing an academic assignment, paper, or

project• Attending a study group required by the

institution where attendance is taken

Faculty Roles

• Communication• Stress importance of reporting

accurate and timely withdrawal dates• Develop a strong rapport for when

unofficial withdrawal information is needed

• Ease Faculty concerns surrounding FERPA

• Discuss Academically related activity

Post-Withdrawal Disbursements

34 CFR 668.22(5)(i)

Disburse Grant Before Loan—Example – If a student is due a post-withdrawal disbursement of

$500 and the student has received $400 of $1,000 in Federal Pell Grant funds that could have been disbursed and $1,200 of the $2,000 in Federal Direct Loan funds that could have been disbursed, the available undisbursed funds are $600 in Federal Pell Grant funds and $800 in Direct Loan funds. Any portion of the $500 post-withdrawal disbursement that the school makes must be from the $600 in available Federal Pell Grant funds.

R2T4 for HOPE/ZELL/ACCEL

• To determine the refund to HOPE, the Eligible Postsecondary Institution must apply the institution’s refund policy, which may or may not be identical to the Federal Title IV return of funds policy, to the student’s original HOPE award for Tuition.

• The Return regulations do not prohibit a school from developing its own refund policy. However, the school must comply with refund policies required by a state or other outside agencies.

• The Eligible Postsecondary Institution must adjust the student’s invoice in SURFER to the new award amount remaining after the refund is calculated within forty-five (45) days of the determination. – b. If the student only received HOPE funds, the Eligible Postsecondary

Institution should return the funds determined to be owed to the HOPE Program within forty-five (45) days of the refund determination.

Example of Hope Return

 Withdrew at the 48% mark – Required to complete return

HOPE Tuition: $ 3390 X 52% (Refund of unearned %) = $1763 Total amount to Refund to GSFC= $ 1763

Adjusted award amount to student’s account= $ 1627

*Note: Round up!

Resources

• 1415 IFAP Handbook Volume 5 – http://ifap.ed.gov/fsahandbook/

attachments/1415FSAHbkVol5Master.pdf

• HOPE Scholarship Program at Public Institutions – http://

www.gsfc.org/main/publishing/pdf/2015/2015-HOPE-PUBLIC.pdf

• 34 CFR 668.22

•

“Q&A”

Thank you for watching this presentation!