Return of Title IV (R2T4)
The basics of R2T4 plus a look at the
rules for programs offered in modules
Return of Title IV Funds
• The requirement for an institution to determine
earned and unearned portions of Title IV aid
when a student ceases to maintain scheduled
enrollment for the payment period or period of
enrollment
Current rules are located in Volume 5
2015-2016 Federal Student Aid Handbook
A student is considered
withdrawn if:
• In the case of a program that is measured in credit hours,
the student does not complete all the days in the payment
period or period of enrollment that the student was
scheduled to complete
• In the case of a program that is measured in clock hours,
the student does not complete all of the clock hours and
weeks of instructional time in the payment period or period
of enrollment that the student was scheduled to complete;
or
• In the case of a non-term or non-standard term program,
the student is not scheduled to begin a class within a
payment period or period of enrollment for more than 45
calendar days after the end of the module the student
ceased attending unless the student is on an approved
leave of absence
Payment Period vs Period of Enrollment
• When a student withdraws from a semester,
trimester or quarter program – payment period
must be used
• When a student withdraws from a non-term or
non-standard term program – the institution has
the choice of using either payment period or
period of enrollment
• Must use the same basis for all students within the
same program
Basic Terminology
Title IV Recipient
• Student who begins attendance and has received
a Title IV grant or loan disbursement or meets the
conditions for a late disbursement
• FWS does not apply to R2T4
• If student never actually begins attendance –
R2T4 does not apply and all Title IV aid must be
cancelled
Basic Terminology
Date of Determination
• Used to determine the various deadlines associated
with R2T4 calculations (see chart on page 5-118 of the
2015-16 FSA Handbook)
• Official withdrawal: the date the student begins the
withdrawal process or provides official notice of intent
to withdraw – whichever is later
• Unofficial withdrawal: the date the institution
becomes aware that the student ceased attendance
• Schools required to take attendance should have a
date of determination that is no later than 14 days
after the student ceased attendance
Basic Terminology
Withdrawal Date
• Used to calculate the amount of earned and unearned
Title IV funds
For institutions not required to take attendance:
• Official withdrawal: the date the student begins the
withdrawal process or provides official notice of intent to
withdraw – whichever is earlier
• Unofficial withdrawal: the date the student last attended
an academically related activity or the midpoint of the
payment period or period of enrollment
• must determine this date no later than 30 days after the end of the
earliest of (1) payment period/period of enrollment (2) academic
year (3) educational program
Basic Terminology
Withdrawal Date
For institutions required to take attendance:
• The withdrawal date is always the last date of
academic attendance as determined from
attendance records
• This date is used for all forms of withdrawal – official or unofficial
• The requirement to take attendance can be
mandated by an outside agency, the institution
itself, or a requirement that can only be met by
taking attendance
Basic Terminology
Academically related activities
• Physically attending a class
• Submitting an assignment
• Taking an exam, completing an interactive tutorial or
participating in computer-assisted instruction
• Attending a school assigned study group
• Participating in an online discussion about academic
matters
• Initiating contact with faculty to ask a question about
the academic subject of the course
Basic Terminology
Aid disbursed
• Title IV funds that were disbursed prior to the
date the institution determined the student
withdrew
Aid that could have been disbursed
• Generally, as long as the condition for late
disbursement has been met, any undisbursed
Title IV funds for the period for which the
calculation is performed
Basic Terminology
Institutional Charges
• Used to determine the amount of unearned aid that
the institution must return
• Includes tuition
• Fees, if required by all students in the program
• Room and board, if contracted with the institution
• Expenses for required course materials, if the student
does not have a real and reasonable opportunity to
purchase the materials from any place but the school
Basic Terminology
Post-withdrawal disbursement (PWD)
• A disbursement of earned funds that was not
received prior to the withdrawal
• A PWD of grant funds does not require a student’s permission.
Student or parent permission must be obtained prior to making a
loan PWD
Unearned funds
• Funds that must be returned to the Title IV
program
• The institution, student or both must return the funds in a specified
order
The R2T4 Process
Determine the date of determination and the withdrawal date
Identify the aid disbursed and aid that could have been disbursed
Calculate the percentage of payment period or period of enrollment completed
Calculate the amount of aid earned
Determine if earned funds are due to the student as a PWD (obtain required permissions)
Determine if unearned funds are due to Title IV programs (due from school or student)
Return all unearned funds within 45 days of date of determination
Defining a Program Offered in Modules
Course(s) in the program do not span the entire length of
the payment period or period of enrollment
• Determination that a program is offered in modules can
change from one payment period to another and is
student specific
• Student is considered to be in a program offered in
modules if he or she is enrolled in one or more of these
courses
Defining a Program Offered in Modules
• Example:
• Two 8 week sessions offered one after the other
• One 16 week session
• A student enrolled in either (or both) of the 8 weeks
sessions is considered to be in a program offered in
modules
• A student enrolled in the 16 week session and either of
the 8 week sessions is considered to be in a program
offered in modules
• A student enrolled only in the 16 week session is not
considered to be enrolled in a program offered in modules
Determining Withdrawal
• Prior to July 2011, a student who completed one course in
one module in a term based credit hour program was not
considered withdrawn, that is no longer the case
• The Department of Education developed a set of three
questions to assist with identifying if a student has
withdrawn from a program offered in modules
• The questions are always accurate, but often it helps to
draw a visual of the enrollment scenario to use while
going through the questions
Determining Withdrawal
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.
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 but a
recalculation of aid may
be required per
regulations and
institutional policies.
If the answer is no, go
to question 3.
Did the student confirm
attendance in a course in a
module beginning later in the
period?
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.
Written Confirmation
• Programs offered in modules allow greater flexibility for enrollment
changes, and those changes often lead to situations that require an
R2T4 calculation
• Written confirmation of intent to return at a later date within the same
period is the only way an institution can avoid having to complete an
immediate R2T4 calculation
• Points to remember:
• Must be positive confirmation from the student
• Must be written (electronic is acceptable)
• Must be obtained “at the time of the withdrawal” – this means close to the date
the student ceased attendance and prior to the time when the calculation must
be completed
• New enrollment for later in the period can be used as confirmation of intent to
return
• Enrollment that was previously scheduled (even if for later in the period) cannot
be used as confirmation of intent to return
The Student Does Not Return…
• When a student confirms intent to return in a future
module within the same period, the institution must
confirm that the student has in fact returned on that date.
If the student does not return:
• The Date of Determination is the date the student certified he or
she would return
• The Withdrawal Date is the last date of attendance, the last date of
attendance in an academically related activity, or the midpoint of
the payment period or period of enrollment (varies based on
requirement to take attendance)
Then the Student Returns…
• If a student returns within the period and prior to the
completion of the R2T4, there is no requirement to
complete the process, but the institution may not delay
the R2T4 process to see if the student will return
• If the R2T4 process is completed, and then the student
returns within the same period (or within 180 days for
clock hour or non-term credit hour programs); the R2T4
calculation must be “undone”
• The original award amounts for Title IV programs must be restored,
with no adjustments required for partial attendance of a module
• Exception: if an entire module was originally scheduled, but the
student never began attendance in the module, then aid must be
adjusted accordingly.
Determining Percentage Completed
Credit hour programs:
Total days completed
Total days scheduled in period
=
% Completed
• Scheduled breaks of 5 or more consecutive days and
days the student was on an approved leave of absence
should be excluded
Determining Percentage Completed
Clock hour programs:
Scheduled hours at withdrawal
Total hours in period
=
% Completed
Determining Percentage Completed
Non-term credit hour programs:
• If student is self paced:
• End date and number of days in payment period or period of
enrollment will be unique for each student
• Must project an end date of the period based on the student’s
progress prior to the withdrawal date; and
• Use projected end date to calculate the days in the payment period
or period of enrollment
Common Modular Scenarios
• Withdrawal and no certification of intent to return:
Date of Determination: 5/22, Withdrawal Date: 5/22
Completed: 5/14-5/22 / Scheduled: 5/14-7/8
Common Modular Scenarios
• Drop future class during a break:
Date of Determination: 3/15, Withdrawal Date:3/11
Completed: 1/17-3/11 / Scheduled: 1/17-5/13 (exclude 7 day break)
Common Modular Scenarios
• Withdrawal from current class and drop future class:
Date of Determination: 5/21, Withdrawal Date:5/21
Completed: 5/13-5/21 / Scheduled: 5/13-8/18
Common Modular Scenarios
• Withdrawal from class and certification of return, does not
return:
Date of Determination: 5/11, Withdrawal Date: 3/5
Completed: 1/17-3/5 / Scheduled: 1/17-5/11 (exclude 7 day break)
Common Modular Scenarios
• Several enrollment changes with breaks in between:
Date of Determination: 5/11, Withdrawal Date: 4/30
Completed: 1/17-4/30 (exclude 6 day break) / Scheduled: 1/17-5/11
QUESTIONS?
Contact Information:
Laura Beer
University of Maryland University College
Email: Laura.Beer@umuc.edu
Phone: 240-684-5643