R2T4 - MASFAP

Report
RAWR……or R2T4
Crystal Bruntz
Director of Financial Aid
Avila University
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
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
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)
Overview of R2T4 Process
Determine student’s
withdrawal date
Calculate percentage of
payment period or period of
enrollment completed
Decide if earned funds are
due to the student through a
Post-Withdrawal
Disbursement; obtain
permissions and credit as
allowed
Determine amount earned
by applying percent
completed to total Title IV
aid disbursed and that could
have been disbursed
Decide if unearned funds are
due to Title IV programs, and
whether they are due from
the student or the school
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
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.
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
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
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 termbased or non term-based program – School can choose
to use either payment period or period of enrollment
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.
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
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


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
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
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
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
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
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
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
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
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 clockhour or nonterm credit hour programs after R2T4 has been
completed, school must “undo” R2T4 calculation
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)
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.
Determining Percentage of Days
Completed
For credit-hour programs:
Days attended
=
Days in period
% completed
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
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
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
THANK YOU!!!
Crystal Bruntz
Director of Financial Aid
Avila University
[email protected]

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