Compliance Concerns: R2T4
2013 Spring Conference
WASFAA Federal Issues Committee
Susan Johnson, UW-Whitewater
Kristina Klemens, UW-Parkside
Julie Waldvogel-Leitner, Moraine Park Technical College
R2T4 Regulation Resources
 Basic calculation
 Common terms
 Modules
 Discussion
R2T4 Regulation Resources
Section 484B of the HEA
Enacted October 7, 1998, as part of the Higher Education
Amendments of 1998
Final Reg published November 1, 1999
Dear Colleague Letter GEN-00-24
Final Reg published November 1, 2002
Dear Colleague Letter GEN-04-03
Dear Colleague Letter GEN-04-12
Dear Colleague Letter GEN-05-16
Final Reg published October 29,2010
Dear Colleague Letter GEN-11-14
IFAP – Program Integrity Q’s & A’s – Return of Title IV
FSA Handbook, Volume 5
Basic calculation
Total # of days completed
= % of aid earned
Total # of days scheduled to complete
% aid earned X Total aid disbursed = Earned aid
If greater than disb aid,
and aid that could
student elig for posthave been disbursed withdrawal disbursement
Total aid – Earned aid
= Unearned aid
Institutional charges X Unearned %
= Amount for school
to return
Basic calculation, cont’d
Unearned aid – Amount school returns
= Amount student
Total loans – Loans school must
= Loans student
must repay
Amount student – Loans student
must return
must repay
= Initial amount of
unearned grants
Total grants X 50%
= Grant protection
Initial amt of grants – Grant protection
= Grants student
must return
Clock hour schools
In a clock hour program, a student is
considered to be a withdrawal if she/he
does not complete all scheduled clock
hours and weeks of instructional time.
 For calculation:
Numerator is clock hours scheduled to be
completed as of the student’s LDA
Denominator is clock hours scheduled to be
completed in payment period/period of
Payment Period/
Period of Enrollment
Payment Period: A school-defined length of time for
which financial aid funds are paid to a student. For
programs using academic terms (semester, trimester, or
quarter), a payment period is equal to a term. For
programs not using academic terms, schools must
designate at least two payment periods within an academic
year that meets all applicable regulations.
Period of Enrollment: The period for which a Stafford or
PLUS loan is intended. Except at nonterm schools, the
period of enrollment must coincide with a bona fide
academic term established by the school for which
institutional charges are generally assessed (e.g, semester,
trimester, quarter, length of the student’s program or
academic year). Also referred to as the loan period.
Withdrawal Date
Withdrawal Date: The date the student
withdraws, as determined by the school.
Date of determination: The date the institution
became aware the student withdrew.
Required to Take Attendance
School is required to take attendance by outside
entity (i.e., accrediting agency)
School itself has a requirement instructors take
The school or the outside entity have a
requirement that can only be met by taking
May apply to a subset of students (i.e., students
in a particular program)
May apply for only a short period of time
Academically Related Activity
Include, but are not limited to:
 Physically attending a class
 Submitting an assignment
 Taking an exam
 Attending an assigned study group
 Participating in an online discussion
 Initiating contact with a faculty member to discuss the
Optional for the school to use
Must be documented by the school (not the student)
Aid That Could
Have Been Disbursed
conditions for a late disbursement were met
before the student withdrew, include as aid that
could have been disbursed
 All Student Aid (including Pell) - ED processed
SAR/ISIR with official (not necessarily a valid) EFC
 Direct Loan – Institution originated the loan
 Perkins/FSEOG - Institution made the award
Do not include a loan if the promissory note has
not been signed at the time you complete the
Institutional Charges
All charges for tuition and fees
Room and board, if contracted with the school
Expenses for required course materials if the
student does not have a real and reasonable
opportunity to purchase elsewhere
Do not include discretionary expenses – parking,
library fines, health services, etc.
Any course which does not span the length of
the payment period or period of enrollment
Even if student is attending full term courses,
they are considered to be in a program offered in
modules if at least one course does not span the
entire payment period
Example: 12 week term, could take combination of courses
3 weeks
3 weeks
12 week course
3 weeks
3 weeks
How to determine if a student enrolled
in module courses has withdrawn
1. After beginning attendance in the payment period or period of
enrollment, did the student cease to attend or fail to begin attendance
in a course he or she was scheduled to attend? If the answer is no, this
is not a withdrawal. If the answer is yes, go to question 2.
2. When the student ceased to attend or failed to begin attendance in a
course he or she was scheduled to attend, was the student still
attending any other courses? If the answer is yes, this is not a
withdrawal; however other regulatory provisions concerning
recalculation may apply. If the answer is no, go to question 3.
3. Did the student confirm attendance in a course in a module beginning
later in the period (for nonterm and nonstandard term programs, this
must be no later than 45 calendar days after the end of the module the
student ceased attending)? If the answer is yes, this is not a
withdrawal, unless the student does not return. If the answer is no, this
is a withdrawal and the Return of Title IV Funds requirements apply.
R2T4 Modules Example 1
Winter is considered a “module” of spring for FA
Winter is from January 7th-February 2nd
Spring is from February 4th-May 17th
 Spring Break is March 24-31st
4 weeks
15 weeks (spring)
19 week total award period
R2T4 Modules Example 1
Student enrolled for 3 credits for winter, 12 for
spring and was awarded full time eligibility.
Winter grade posted after spring started, student
received “FN” grade indicating unofficial withdraw
To determine if an R2T4 was required, I:
 Contacted professor’s for spring.
 Student was attending for spring, therefore no
R2T4 required
 No aid adjustment was required because
student was still full time
R2T4 Modules Example 1
Shortly after contacting the professors, the student
fully withdrew for spring
An R2T4 was required. To correctly calculate, I:
 Contacted professor for winter to determine
how long the student attended
 Determined how many days student attended
for spring
 Determined total days of award period
R2T4 Modules Example 1
Student attended:
 7 days for winter +
 10 days for spring
 17 total days
Award Period was:
 130 total days  8 day spring break
 122 total days
Total # of days completed
=17 days
# of days scheduled to complete =122 days
=13.9% earned
R2T4 Modules Example 2
Summer Term consists of 12 weeks, with multiple
modules (3 week, 6 week, 9 week, or full term
Student enrolled in 2nd 3 week and 3rd 3 week:
3W, Module 2: June 18 – July 6
3W, Module 3: July 9 – July 27
Student completed Module 2 and dropped Module 3
on July 6. Does this require R2T4?
R2T4 Modules Example 2
Yes! When a student withdraws and
completes on the same day, R2T4 is
Total # of days completed
# of days scheduled to complete
Earned aid is 47.5%
= 19 days
= 40 days
One more thing to consider. . .
R2T4 Modules Example 2
Student’s aid:
Pell Grant: $1387 (half time)
Unsub: $2006 (net $1996)
Student did not begin attendance in all classes, so
recalculate Pell first.
Pell: $694 (less than half time)
Unsub: $1996
Total Aid: $2690 X 47.5% = $1277.75 earned
R2T4 Modules Example 3
Summer term is 12 weeks, consists of
multiple enrollment options.
 Student enrolled in 3 4-week module
Mod 1: May 20-June 21
Mod 2: June 24-July 19
Mod 3: July 22-August 16
4 week
4 week
4 week
Total: 12 Week Summer Term
R2T4 Modules Example 3
Student total enrollment was 9 credits, 3
per 4 week mod course
 On June 15th, student DROPPED course
from mod 2 (June 24-July 19th), but did
NOT drop a course from mod 3.
 Is an R2T4 required?
Dropped Mod 2 on 6/15
R2T4 Modules Example 3
To find out, we:
 Contacted the student
 Are
you attending mod 1? –YES
 Are you going to be attending mod 3? –YES
No R2T4 required because student is
maintaining enrollment, but still must
adjust aid
R2T4 Modules Example 3
Student award:
 Pell-$2081
 Unsub-$2,000
Since student is now ½ time instead of ¾
time, reduced Pell to $1,387
 No revision to loan eligiblity