Implementing Academic
Innovation –
Non-Traditional Calendars
Presented by:
Rebecca Flake
WASFAA
Conference
April 14, 2014
© 2013 Cooley LLP, Five Palo Alto Square, 3000 El Camino Real, Palo Alto, CA 94306
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Agenda

Definitions

Academic Calendars

Modules and Intersessions

Standard Term with Modules and Non-standard Term,
Substantially Equal


Non-Standard Term, Not Substantially Equal and NonTerm


Awarding, Disbursing, and R2T4
Awarding, Disbursing, and R2T4
Things to Consider
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Definitions
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Definitions

Term


Academic Year


a period in which all classes are scheduled to begin and
end within a set time frame; generally a semester or
quarter
the number of instructional weeks and credits or clock
hours a full-time student must attempt in a school year
Instructional Week

any period of 7 consecutive days in which at least 1 day
of regularly scheduled instruction, examination, or (after
the last day of classes) at least 1 scheduled day of study
for exams occurs
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Definitions

What is an academic calendar?

How an institution defines the calendar in which instruction is offered to
students

Must be defined for each program of study

Can vary by program
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Academic Calendars
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Academic Calendars

Standard Term –

Quarter ranging between 10 and 12 weeks;
but at least 9 weeks

Semesters ranging between 14 and 17 weeks

Offered on set calendar

Term lengths do not vary by more than 2
weeks (intersession exception)

If quarters, award quarter credits; if semester,
award semester credits
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Academic Calendars

Standard term, continued-

Combine modules to make a term

Can attach an intersession

The payment period is the term and not the individual
module (if module changes to non-standard term)

May award Title IV for some repeat coursework, if
otherwise eligible
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Academic Calendars

Non-Standard Term, Substantially Equal –

Quarter or semester which are longer or
shorter than standard length; term lengths do
not vary by more than 2 weeks

Offer quarter credits in a semester or semester
credits in a quarter

At least 9 weeks

Generally administered the same as standard
term
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Academic Calendars

Non-Standard Term, Not Substantially Equal

Quarter or semester which are longer or shorter
than standard length; term lengths vary by more
than 2 weeks

Offer quarter credits in a semester or semester
credits in a quarter

Administered as non-term
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Academic Calendars

Non-Term

Programs offered in clock hour

Overlapping terms or courses

Self-paced programs

Floating start and end dates

Most difficult to administer
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Academic Calendars
A program is required to be clock hours when 
Clock hours are required in the Federal or State approval or
licensure process required to offer the program
 Exception for limited program component

Completing clock hours is a requirement for graduates to
apply for licensure or the authorization to practice the
occupation that the student intends to pursue

The credit hours awarded for the program are not in
compliance with the definition of a credit hour in 34 CFR
600.2

The institution does not provide the clock hours that are the
basis for the credit hours awarded for the program or each
course
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Modules and Intersessions
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Modules and Intersessions

What is a module?

A course that does not span the entire length of the term

Compressed course that is offered over a shorter timeframe
than the traditional course offering

Must not overlap semesters to remain standard term
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Modules and Intersessions

Modules continued:

Generally the same amount of academic work in a shorter
instructional period

Modules can work in a standard term calendar

Student may start modular course after term begins

The student may skip a module and not be withdrawn
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Modules and Intersessions

What is an intersession?

A period of time in which short optional courses are offered
between longer standard terms

May only be attached to a standard term and make it longer than
15 weeks

Should not start or end during the standard term

Does not change a standard term into a non-standard term unless
the intersession courses are required and not optional
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Modules and Intersessions

Intersessions continued –

Must attach to the same term for all students in the same
program

Changes the end date of the loan period and R2T4 payment
period, if the student enrolls

Credits for the intersession course are included in the enrollment
status for the attached longer term – must include the
intersession when awarding, if enrolled
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Modules and Intersessions

House with a Shed or Addition Analogy
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Standard Term with Modules
and
Non-Standard Term,
Substantially Equal
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Awarding - Standard Term with Modules and
Non-Standard Term, Substantially Equal




Generally similar awarding with the exception of intersessions
attachment to the standard term
Enrollment status for courses enrolled in the term – modular,
full term, and intersession
Enrollment status may include limited repeat coursework –
even within the term if needed
Cost of attendance is adjusted for periods of non-attendance –
indirect costs and tuition and fees may differ from student to
student
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Awarding - Standard Term with Modules and
Non-Standard Term, Substantially Equal

Student may attend only the intersession and receive Title IV if
they have sufficient enrollment status and COA

Pell Formula 1 or 3

Must recalculate Pell and CB for courses the student does not
start – during the term, at the end of the term, or upon withdrawal

Modular schedule may increase number of recalculations

Enrollment changes late in the term must be considered
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Awarding - Standard Term with Modules and
Non-Standard Term, Substantially Equal

May award loans for single term

The minimum loan period is the entire term even if the student
only attends a single module

Loan Period: Scheduled Academic Year (SAY), BorrowerBased Academic Year 1(BBAY-1), Borrower-Based
Academic Year 2 (BBAY-2)

Loan period end date will include the intersession as part of
the term, if enrolled

Prorate loan awards only for final period of study
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Disbursement - Standard Term with Modules and
Non-Standard Term, Substantially Equal

One disbursement of each fund type by term

Multiple disbursements within the term
if a single payment period loan and the school does not have a low
default rate;

if it is in the best interest of student (by module) or;

the non-standard term is longer than 4 months

Up to 10 days prior to the start of the term or later module

Disbursement for registered coursework if paid early and actual
coursework if paid after class start
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Disbursement - Standard Term with Modules and
Non-Standard Term, Substantially Equal

Delay disbursement until student begins their first module within
term

Should not delay disbursements until student begins all courses
or at least half-time

Clearly communicate disbursement policy to students enrolled
in modules who will not receive disbursement at the start of the
term
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R2T4 - Standard Term with Modules and NonStandard Term, Substantially Equal



Perform R2T4 calculation when a student stops attending all
courses at any point in the term
Official and unofficial withdrawals – all unearned grades
Calculation not required if student provides notification of intent
to attend a module later in term unless they do not return
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R2T4 - Standard Term with Modules and NonStandard Term, Substantially Equal


Review enrollment status for Pell recalculation
No recalculation required for loans unless not disbursed –
consider revised enrollment status for loan PWD

If attendance taking or academic engagement monitoring - use
the last day of attendance or last day of academic related activity
as withdrawal date

May use midpoint if non-attendance taking or academic
engagement monitoring
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R2T4 - Standard Term with Modules and NonStandard Term, Substantially Equal

Use modules enrolled at point of withdrawal to calculate
total days; excluding days on scheduled break and LOA

If only enrolled in modules 1 and 3, exclude days in module
2 when calculating total days

If enrolled in both term courses and module courses, use
the longer period to calculate total days

Calculate tuition liability for enrolled modules based on
institutional policy
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Non-Standard Term, Not
Substantially Equal
and
Non-Term
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Awarding- Non-Standard Term, Not
Substantially Equal and Non-Term

Awards based on the lesser of a full academic year, program
length or remaining period of study

Academic year awards are usually full-time

Pell Formula 4; Formula 5A for Correspondence

Must prorate all awards for periods less than a full academic
year
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Awarding- Non-Standard Term, Not
Substantially Equal and Non-Term

Payment period for loans only in final period of study

May not award funds for repeat coursework

BBAY 3

Advance grade level after successful completion of prior
academic year
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Disbursement - Non-Standard Term, Not
Substantially Equal and Non-Term

Pell may be disbursed by payment period

Loans limited to two disbursements at start and midpoint

Student must successfully complete the prior payment period in weeks
and credit/clock hours

Failing grades delay disbursement

Disbursement up to 10 days before payment period if prior period is
successfully completed
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R2T4 - Non-Standard Term, Not
Substantially Equal

Perform R2T4 calculation when a student stops attending at
any point during the payment period

If unequal disbursement schedule, use longer loan payment
period and project the remaining Pell disbursement for the
same period

Calculation not required if student provides notification of intent
to return within 45 days unless they do not return
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R2T4 - Non-Term

Intent to return to a later module within 45 days

The payment period end date must be modified for additional
coursework required due to failure

For clock hour programs, the numerator includes the
scheduled clock hours to have been completed through the
last day of attendance in the payment period; denominator is
all clock hours in payment period
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Things to Consider
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Things to Consider

System programming considerations to accommodate nontraditional calendars:

Alternate course start and end dates within the term

Varying COA/need calculations

SAP calculations to consider all courses within the term

Transcript consistency

R2T4 considers alternative start and end dates
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Things to Consider

Drop and add periods for modules and intersession

Tracking initial attendance in all modules and intersession

Varying disbursement dates

Varying processing schedules

Crossover award tracking
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Things to Consider
Operational Considerations:

Alternative billing processes and impact on institutional refund
policy

Impact on state-funded programs

New policies and procedures

Communication with impacted offices/departments

Communication with students

Implementation and compliance monitoring
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Things to Consider

Communication with students:

The possible availability of Title IV funds from the earlier award
year if they start classes in a cross over period and the
required application process; may need to complete two
FAFSAs

The delay of disbursement of funds until their module begins

The SAP evaluation process is not impacted by modular
courses – no early evaluations
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Questions?
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Thank You!
Rebecca Flake
Senior Advisor
Higher Education Services
Cooley, LLC
202-776-2343
rflake@cooley.com
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