PowerPoint Presentation

The Basicswith a Touch of ModulesReturn of Title IV Funds(R2T4):2015 NJASFAA Fall ConferenceAtlantic City, NJNovember 12, 2015

Craig D. Rorie, Training OfficerFederal Student AidU.S. Department of Education 1AgendaR2T4 BasicsHow the R2T4 Calculation WorksReturning FundsPost-Withdrawal DisbursementsOther ConsiderationsModules ResourcesExamples

2 23Basics - R2T4 ConceptStudent earns Title IV aid through attendancePercentage of aid earned is equal to the percentage of the payment period or enrollment period completedIf attend one day, R2T4 applies

AFTER the 60% point in a payment period or period of enrollment, a student has earned 100% of scheduled Title IV funds

Schools own refund policy or other outside policies do NOT impact the amount of Title IV aid earned under R2T4 calculation

34Basics- R2T4 PremiseIf school has disbursed more aid than the student has earned, money is returned to the programs

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

45Basics To R2T4 or Not to R2T4?Title IV eligible students who begin attendance and completely withdraw, or otherwise cease attendingStudent must have actually received Title IV loan funds or met the conditions for a late disbursement (Post-Withdrawal Disbursement)

If student enrolled but never attended any classes (34 CFR 668.21)Student did not establish eligibility for any fundsAll Title IV aid disbursed must be returned

5Basics - Rounding Rules for %Calculate out to 4 decimal places45 days / 101 days = .4455199 hours / 450 hours = .4422

Round to third decimal place.4455 = .446 = 44.6%.4422 = .442 = 44.2%6

67Basics - Rounding Rules for $ AmountsRound to the nearest penny$2,346.00 x 44.6% = $1,046.316 or $1,046.32$2,346.00 x 44.4% = $1,041.624 or $1,041.62

Disbursement or refund may be rounded to the nearest dollar$1,046.32 = $1,046$1,041.62 = $1,042

78Basics - Consumer InformationSchool must provide to prospective and current students:

Any refund policy with which school must complySchools tuition refund policyRequirements for treatment of Title IV funds after withdrawalProcedures for official withdrawalOffice(s) accepting official withdrawal notices 89Top Ten Program Review and Audit finding

R2T4 ProblemsLate ReturnsR2T4 ErrorsR2T4 not done

One of the highest liability producing deficiencies

Basics- R2T4 & Compliance

10How the R2T4 Works Key ConceptPayment Period or Period of EnrollmentStandard term-based program must use payment period (term)

Nonstandard term or nonterm program may choose either payment period or period of enrollmentMay choose on a program-by-program basisMust be consistent with method usedTitle IV aid and institutional charges (generally) calculated on a payment period or period of enrollment basis

10How the R2T4 Works Key ConceptDate School Determined Student WithdrewOfficial Withdrawal:Date begins official withdrawal process; orProvided official notification to designated office

Unofficial withdrawal: (no notification)No later than 30 days after end of the EARLIER of:The payment period (or period of enrollment)The academic year, orThe students educational programIf required to take attendance, determine no later than 14 days after students Last Date of Attendance (LDA)

11Date clock starts ticking for returns, notifications and Post Withdrawal Disbursement (PWD)

11How the R2T4 Calculation WorksStep One: The institution determines the precise amounts of Title IV aid for which a student was eligible at the time of the withdrawal, including amounts disbursed and amounts that could have been disbursed

12 12 13Aid That Could Have Been DisbursedTo include aid, must meet conditions for a late disbursement (668.164(g)(2)) At time student withdrew - ED processed a SAR or ISIR with official EFCPerkins/FSEOG made awardDirect Loans originated

However, aid listed in the could have been disbursed section CANNOT actually be disbursed if:1st time borrower withdraws before the 30th day of the academic program (default rate waivers apply)2nd and subsequent disbursements UNLESS the student graduated or completed the loan period Borrower did not sign the MPNValid ISIR requirements

13How the R2T4 Works Clock HourStep Two: The institution calculates the percentage of the period that the student was scheduled to complete upon withdrawalIf greater than 60%, the student earned 100% for the periodNumerator: Number of hours the student was scheduled to completeDenominator: Total hours in the period

14 14How the R2T4 Works Credit HourStep Two: The institution calculates the percentage of the period that was completedNOTE: If greater than 60%, the student earned 100% for the periodNumerator: Number of days attended (completed) in the periodDenominator: Total number of days in the period

15 1516Step 2 - Calendar Days Credit-HoursCount every day, including weekends and holidays, except:Scheduled break of five or more consecutive days when no classes are offeredDays of leave of absence are not included in total daysIf modules, count all days in modules student scheduled to attend

16

17STEP 2: Withdrawal Date

Always has the option of using the date of students last attendance at an academically related activity as documented by the schoolSchool Not Required to Take AttendanceSchool Not Required to Take Attendance 17STEP 2: Withdrawal Date School Not Required to Take AttendanceOfficial Withdrawal or Unofficial WithdrawalOfficial WithdrawalDate student began schools withdrawal processDate student otherwise provided official noticeOfficial notification provided to a designated school official in official capacityIn writing or orallySchool must document oral notificationsIf both dates triggered, use the earlier date

18Date used to determine percentage of TIV aid earned 18STEP 2: Withdrawal Date School Not Required to Take AttendanceUnofficial withdrawalStudent withdraws (drops out) without notifying the school; use:

Midpoint in period if student did not notify school orIf student didnt notify due to circumstances beyond students control, the date related to that circumstance illness, accident, grievous personal loss, etc.19 19If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the institution must assume, for Title IV purposes, that the student has unofficially withdrawnUNLESS the institution can document that the student completed the periodMay develop a grading policy to assist with evaluation (F, U, FA, FW, etc)

20Unofficial Withdrawals - All F Test

STEP 2: Withdrawal Date School Not Required to Take AttendanceDate school determines leave began (if student did not return from approved leave of absence)An approved leave of absence must meet EDs guidelines*Schools may have a leave of absence policy different from EDs guidelinesStudents approved for leave under a policy that doesnt meet EDs guidelines are considered withdrawn and an R2T4 must be calculated at the time the leave begins21*Usually not applicable to term-based programs 21Attendance at an academically-related activityIncludes:Physically attending class with direct interactionSubmitting academic assignmentTaking exam, interactive tutorial or computer-based instructionAttending school assigned study groupParticipating in online discussions about academic matters and/or initiating contact with faculty to ask questions about subject studied

22Credit Hour

Attendance at an academically-related activityDoes NOT include:Living in school housingUsing school meal planAcademic counseling or advisementLogging into an online course without active participationStudents certification of attendance without school documentation is not acceptable

23Attendance

24STEP 2: Withdrawal Date

School Required to Take AttendanceIF An institution is required to take attendance by:An outside entity (such as an accrediting or State agency) OR the institution itself requires instructors to take attendance (ALWAYS CLOCK HOUR PROGRAMS)Either at the program/department/institutional levelAn outside entity OR the institution has a requirement that can only be met by taking attendance

THEN... withdrawal date is taken from attendance recordsAlways the last date of academic attendance

24If required to only take attendance for some of its students, the institution would use attendance records to determine withdrawal dates for those studentsIf required to only take attendance for a limited time period, the institution would use attendance records to determine withdrawal dates during limited time periodIf required to take attendance on a specific date for census reporting requirements, the institution is NOT considered to be required to take attendanceIf faculty choose to take attendance (but not required), then school is NOT required to take attendance

25Required to take Attendance

A leave of absence (LOA) is a temporary interruption in a program of study instead of a WDConditions for an Approved LOA:Formal written policyStudent followed the formal policy in requesting the LOAThere must be a reasonable expectation that the student will return from the LOAThe school must approve the requested LOA in accordance with its policyThe student may not be charged additional institutional chargesThe number of days on an approved LOA cannot exceed 180 days within a 12-month periodLoan recipients must be told about the effects on their grace period if they do not return Leave of Absence26

26For non-term credit-hour programs the student does not have to resume training at the same point the student began the LOA

For standard term or non-standard term programs the student must resume training at the same point the student began the LOA

Leave of Absence27

27How the R2T4 Calculation WorksSteps Three and Four: The percentage completed is multiplied by the total amount of Title IV aid for which the student was eligibleIf the amount earned is less than the amount disbursed, a return to the Department is requiredIf the amount earned is greater than the amount disbursed, a PWD is required

28 28How the R2T4 Calculation WorksStep Five: If a return is required, the institution determines the amount of unearned Title IV funds that it is required to return

The amount of funds due from the institution is calculated by adding all the institutional charges incurred by the withdrawal date, then multiplying that total by the percentage of the period the student did not complete

29 2930Institutional ChargesCharges include:Tuition and feesRoom and board (if contracted with school)Course materials if no real and reasonable opportunity to purchase outside of school

Charges initially assessed student for the payment period/period of enrollmentOnly adjusted by changes prior to withdrawal

30How the R2T4 Calculation WorksStep Six: Once the institution determines the total amount of unearned Title IV aid that must be returned to the Department, the institution must return funds in the statutory order (i.e. loans, then grants)

31 31

32Timeframe to Return Funds

Calculation must be completed within 30 calendar days of the date of determination of withdrawalReturn funds to Direct Loan program as soon as possible, but no later than 45 calendar days after the date of determination of withdrawal

3233Step 8: Repayment of Students LoansStudent is responsible to repay any loan funds not returned by the schoolLoans are repaid in accordance with terms of the promissory note

3334Step 10: Return of Funds by StudentAny grant repayment due from student is considered an overpaymentStudent is responsible for repaymentAmounts of $50 or less in any program are set asideGrant 50% protectionLaw specifies order of Title IV programs to which funds must be returned 3435Grant OverpaymentSchool must notify student within 30 days of schools determination of withdrawalStudent retains Title IV eligibility for 45 daysDuring that time, he must either:Repay in full to schoolMake satisfactory arrangements to repay with school (schools option)Make satisfactory arrangements to repay with Department of EducationStudent referred to ED within 45 days if not paid in full or no payment arrangements with school

3536Post-Withdrawal Disbursements (PWD)When Title IV aid disbursed is less than Title IV aid earnedMust meet Late Disbursement rules Sample worksheet in FSA Handbook Box J on R2T4 Worksheet

3637Notification of PWDSchool must provide written notification within 30 days of date of determination of withdrawal

Must identify type and amount of fundsAmount crediting students account and/or direct disbursements to student/parentMust explain option to accept or decline some or all of fundsMust explain obligation to repay any loan funds disbursedMust provide a deadline for responseAt least 14 days

3738PWD - Grant FundsNo student confirmation required Disbursed directly to student - as soon as possible, but no later than 45 calendar days after date of determination

Disbursed as credit to account within 180 days after date of determination

3839PWD - Loan FundsMust receive confirmation from the student or parent borrower prior to disbursement Does not have to be in writing but must be documentedIf received after deadline, school may choose to honor a late response

Direct disbursements to the student or parent must be made as soon as possible, but no later than 180 days after date of determination

3940Special CircumstancesCredit BalancesVerificationDeath of a StudentInadvertent overpaymentsFailing to earn a passing gradeTerms with modulesProrating charges Student returning within 180 days or transferring into a new program in clock hour and nonterm credit hour programs

40Verification and R2T4If verification not complete within timeframe to meet R2T4 deadlines, school excludes aid subject to verification from calculationIf verification is then completed after R2T4 deadlines but before verification deadlines, school must recalculate R2T4 including verified amounts as aid that could have been disbursed4141

41Hold all Title IV Credit Balances until R2T4

Credit Balance is Aid Disbursed

Determine if Credit Balance changes because of a Refund Policy or R2T4

Use Credit Balance to repay Grant on behalf of student

Release Credit Balance within 14 days42Title IV Credit Balances

42R2T4 & Modules- Definition43668.22(l)(6)when a course or courses in program do not span entire length of payment period (term) or period of enrollmentDoesnt matter what modules are called at the institutione.g., mini-terms, J-terms, mini-mesters, mini-sessions, modules....

43Different Modules in a 16-week Term444 weeks4 weeks4 weeks4 weeks8 weeks8 weeks5 weeks

5 weeks

5 weeks

8 weeks

3 weeks

5 weeks

3 weeks3 weeks3 weeks3 weeksFull term courses16 weeks These are examples of modules that fit into a standard term. As you can see, aside from term length courses (courses that go the full length of a term), a school may have many combinations of modules within the beginning and ending dates of a defined term.

REMEMBER - Having different modules with different lengths starting and ending at different times within a term could apply to any term standard or nonstandard.44Withdrawal Defined45Student does not complete all days scheduled to complete within the payment period/term (whether official or unofficial withdrawal)

If no passing grade in last scheduled course/module, school must demonstrate student completed period

An administrative withdrawal initiated by the school is considered an official withdrawalA school may drop a student from a class in a future module because the student failed a prerequisite class in a prior module

45Calendar Days - Credit Hour Modules Total calendar days include all days in which the student was scheduled to attendDays of attendance in courses count regardless of whether module(s) were completedExclude scheduled breaks of at least 5 consecutive days when student is not scheduled to attend a module or other course Includes allowable breaks between modules (as long as not attending other courses during the break)When a student who has made schedule changes withdraws, do not count attendance in courses officially dropped prior to ceasing attendance46 46Impact of Enrollment Status ChangesAdjustments to a students enrollment status made after a student has ceased attendance have no bearing on the R2T4 calculationsIf a student enrolled in 3 modules, completes one, and then drops the remaining two after ceasing attendance, all days in all three modules will be included in the R2T4 calculationThis can apply to situations where a student drops all future modules during a break between modules47 47Impact of Enrollment Status ChangesIf a student drops all future courses on the same day they withdraw from a current module (or complete a module last day of module), it is considered a withdrawal and all days in all modules the student was scheduled to attend must be included in the R2T4 calculation48 48Written Confirmation Of Return49Student in a modular program not considered a withdrawal if:Provides written confirmation of intentMust be provided at the time of withdrawal Can be paper or electronic processRegistration for future modules does not constitute written confirmationStudent may change return date in writingMust provide change prior to original return date

49 Written Confirmation Of Return50Nonstandard term and Non-term programsStudent considered to be withdrawal if not scheduled to begin another course in period of enrollment for more than 45 calendar days

45 days measured from end of module ceased attending

50 Written Confirmation Of Return

51Student considered to be withdrawal if does not return as scheduled

Withdrawal date is retroactive to when written confirmation was originally providedDetermine withdrawal date and days of attendance as if written confirmation was never providedThe date the student was scheduled to return is the date of the schools determination of withdrawal

51Return After Withdrawal52If returning in the same payment period, the student is treated as if did not cease attendanceThe school must undo the R2T4 calculationRestore students original amounts with no adjustment for partial attendance of a moduleExcept if a student never began all of their coursesAdjustments may need to be made to the original Title IV award amounts, such as Pell Grant recalculations

52 R2T4 and Pell Grant Recalculation

53Student doesnt begin attendance in all classes in a termIf a student does not begin attendance in all of his or her classes, resulting in a change in the students enrollment status, your school must recalculate the students award based on the lower enrollment statusIf a school learns a student did not begin attendance in all courses and an R2T4 calculation is required, FIRST perform the Pell recalculation and then include the adjusted Pell amount in the R2T4 calculationThe Pell recalculation is a separate and distinct process from the R2T4 calculation 1st remember in term based settings there is a mandatory Pell recalculation if a student does not start attending enough classes to account for the enrollment status for which he was paid FT; time, etc.

Modular courses within terms often have to deal with this issue because students are starting different modules at different times throughout the term. Schools who pay Pell upfront for all classes registered for in the term must monitor students throughout the term to ensure they start all the classes within all modules that made up their Pell enrollment status.

53 Did the Student Withdraw?Did the student cease to attend before completing, or fail to begin attending, a course scheduled to attend? If yes, go to question 2If no, student is not a withdrawal

When ceased to attend or failed to begin attendance in a scheduled course, was the student attending other courses? If yes, student is not a withdrawalIf no, go to question 3

Did the student confirm attendance in a later module in the payment/enrollment period (45 day rule, if applicable)? If no, student is a withdrawalIf not a withdrawal, Pell recalculations may apply

54

54 54Resources & References55

55R2T4 References56FSA Handbook, Volume 5Program Integrity Q & A website http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/integrity-qa.htmlR2T4 website available through FAA Access to CPS Onlinehttp://www.faaaccess.ed.gov/Dear Colleague Letter GEN-11-14 (July, 2011)34 CFR 668.22 (R2T4); Federal Register October 29, 201034 CFR 690.80 (Pell recalculation)FSA Assessmentshttp://www.ifap.ed.gov/qahome/qaassessments/returntivfunds.html 56

Questions?

57

57Region II Training Officer58Nautochia Webb646-428-3758nautochia.webb@ed.gov

Region II: NJ, NY, PR, Virgin Islands 58Region III Training Team59Amber Johnson202-377-3369amber.johnson@ed.gov

Craig Rorie215-656-5916craig.rorie@ed.gov

Region III: DC, DE, MD, PA, VA, WV 59Training FeedbackTo ensure quality training we ask all participants to please fill out an online session evaluation

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This feedback tool will provide a means to educate and inform areas for improvement and support an effective process for listening to our customers

Additional feedback about training can be directed to joann.borel@ed.gov

60 60R2T4 Examples &Case Studies:

61

61Case Study Richard ShermanSchool Profile: Academic Yr. = 30 weeks and 24 credit hoursPayment Period = 15 weeks Withdrawal type = Unofficial WDPeriod Start Date: September 1 WD date = 50%Institutionally Schedule Breaks = none Date of Determination = Dec 16thAttendance taking = Not requiredMethod for matching FSEOG = Fund specificPeriod used in the Return calculation = Payment Period COA Profile:Title IV Award Profile:Tuition & Fees:$4,000/semesterPell Grant:$2,750/semesterRoom:$1,000/semesterFSEOG$2,000/semesterBoard:$1,000/semesterNet Unsub DL $1,930/semesterBooks & supplies$ 500/semester

62 62Case Study Richard ShermanOther informationRichard never officially withdrawsAt the end of the term, the institution discovers that he failed all of his coursesOn Dec 16th after faculty are consulted the office responsible for R2T4 determined that the last time Richard was at an academically-related event was Oct 10thPayment period start date = September 1Payment period end date = December 950% point = October 20Date of Determination = December 16th

63 63Case Study Step 1

64 64Case Study Steps 2 & 3

65 65Case Study Steps 4 & 5

66 66Case Study Step 6

67 67Case Study Steps 7 & 8

68xxx-xx-xxxx 68Case Study Steps 9 & 10

69 69Summer Module Example 70Fall and Spring: standard termsAll courses last for full 15 weeks and arenot considered to be offered in modules

Summer: three 5-week sessions (combined to be a standard term offered in modules)Students can enroll in any one, two or all three summer sessionsStudents in the 5-week summer sessions are considered enrolled in a program offered in modules since none of the sessions span the entire length of the 15-week term The fall and spring semesters are regular semesters, meaning that all courses last the full 15 weeks of the semester. But the schools summer term is really three 5-week sessions offered consecutively. The aid office combines them into a term for Title IV purposes. In the summer, a student may enroll in any of the three sessions, or a combination of them. Because these 5 weeks courses do not span the entire length of the term, 15 weeks, this is considered to be modular. Summer Module Example Session 15 weeksSession 25 weeksSession 35 weeks33 days33 days33 daysStudent enrolls in all three summer sessions. Completes session 1, begins session 2, and stops attending on day 10. No notification of withdrawal provided, or confirmation of return.

R2T4 calculation required, after recalculating Pell GrantWithdrawal date: day 10 of session 2 (if required to take attendance); 50% point of enrollment period or last known date of attendance (if not required to take attendance)Number of days in period = 103 days

2 days2 days71 Heres a visual. Three 5 week sessions of 33 days each, with 2 days of no school in-between modules (the weekends). Our student enrolls for a course in each of the three sessions. He completes his course in session 1. Student begins session 2, but stops attending after 10 days and withdraws from session 2. At this point, student is a Title IV withdrawal and an R2T4 calculation must be done. This is VERY different from prior rules (pre-7/1/11) that did not consider the student to be a Title IV withdrawal because he had completed a course in the term. The period of enrollment is the entire 103 days of the combined summer term. That means that the student attended for 43.7% of the term.

But, we said the student was enrolled for session 3. The students pre-registration for the third session is not enough to override the R2T4 requirement. However, if the school collects written confirmation from the student, at the time of withdrawal from session 1, that he intends to return for the third session, an R2T4 is not required.

So, they do collect the confirmation at the time of withdrawal from session 1. All long as the student returns for the third session and completes it, no R2T4 is required. If the student does not return for the third session, an R2T4 is done using the same information as on the screen. You use the days in the combined summer term.

What if the student returns for session 3, then withdraws after a week? In this case, an R2T4 is done using the withdrawal date from session 3 and the same 103 day period of enrollment.

R2T4 Studies University (RSU) Scenario72Module 133 daysModule 233 days15-week Full Term 103 days.

9/06 10/0810/11 11/1211/15 12/179/06 12/17Module 333 daysStandard Term Semester CalendarTerm is 15 weeks, 103 daysCourses also offered in 5-week, 33-day modules2 days2 days Heres the calendar for RSU. We will use it for the remaining modular examples.

The school is on a semester calendar, with a 15 week semesters. Many courses span the entire 15 weeks, September 6 to December 17. The term is 15 weeks and 103 days. But shorter courses are also offered. BTU calls them parts of the term. Each part lasts for 33 days, and students may take courses in any part of combination of parts. The dates of the parts of the term are on the slide.

RSU Example 1 732 days2 days9/06 attends 6 credits in Full Term; enrolled in Modules 2 and 39/28 withdraws from 3 credits in Full Term11/12 withdraws from 3 credits in Full Term10/11 begins 3 credits, Module 2 11/12 completes 3 credits, Module 211/12 withdraws from 3 credits, Module 315-week Full Term (9/06 12/17): 103 daysModule 133 daysModule 233 days 9/06 10/0810/11 11/1211/15 12/17Module 333 days Our first RSU exampleStudent is enrolled for 6 credits in the full semester. So, he is scheduled to attend school from September 6 to December 17. He is not enrolled in Part 1 courses, but is enrolled in 3 credits in Part 2 and 3 credits in Part 3.

Student begins attendance on September 6 in all 6 credits. On September 28, he withdraws from one full term course of 3 credits. He is still attending other full term course. His enrollment period is still through December 17.

On October 11, he begins his course in Part 2. And completes it on November 12. But, also on November 12, the student withdraws from his remaining 3 credits in the full term and withdraws from the 3 credit class in Part 3.

Think about Pell for a minute. The student never attended his 3 credit course in Part 3. You must return any Pell paid for that course. That makes his Pell three-quarter time.RSU Example 174Enrollment ends 11/12 with completed course and official withdrawalWas to attend until 12/17Pell recalculation as necessary (module 3)R2T4 requiredWithdrawal date is 11/12, 68 daysEnrollment period is 9/06 12/17, 103 days68/103 = .6602 = 66.0%

When does his enrollment end? November 12. He has one completed course and an official withdrawal. He was enrolled to attend through December 17, so an R2T4 is required. He did not attend for all of the days for which he was enrolled. The withdrawal date is November 12, and if we count days on the calendar, that is 68 days in school. His enrollment period is 103 days. 68 / 103 = .6602 or 66% of the term.

An important point here is the Department has said that if a student completes a course and withdraws or drops on the same date, we are considering the student to be a withdrawal.

Rounding?74 RSU Example 2759/06 attends 6 credits in Full Term; enrolled in Modules 1 and 39/22 withdraws from 3 credits in Full Term12/17 completes 3 credits in Full Term

09/06-10/08 begins attendance in and completes 3 credits, Module 111/15 begins 3 credits, Module 3, and withdraws 12/0715-week Full Term 103 days2 days2 daysModule 133 daysModule 233 daysModule 333 days 9/06 10/0810/11 11/1211/15 12/1715-week Full Term (9/06 12/17): 103 days Lets look at another RSU example. Our student is enrolled for 6 credits in the full term, September 6 to December 17. She is also enrolled in a 3 credit course in Part 1 and a 3 credit course in Part 2. Student is not enrolled in Part 2.

She begins her classes on September 6, as scheduled. Two courses in the full term and one course in Part 1. On September 22, she withdraws from a 3 credit course in the full term. Still attending with a end date of December 17. On October 8, Part 1 and she completes her course. She is not enrolled in Part 2 but is still attending a 3 credit course in the full term.

On November 15, she begins her course in Part 3 and then withdraws from it on December 7.

On December 17, she completes her 3 credit course in the full term.RSU Example 276Enrollment ends 12/17 with completed Full Term courseNo R2T4 required

So, her enrollment ends on December 17 with a completed course. She attended all of the days for which she was enrolled. She is not a Title IV withdrawal. No R2T4 is required.76RSU Example 3779/06 attends 6 credits in Full Term; enrolled in Mod 19/14 withdraws 6 credits in Full Term

9/06 begins attendance in 3 credits, Module 19/24 withdraws from 3 credits, Module 115-week Full Term 103 days2 days2 daysModule 133 daysModule 233 daysModule 333 days 9/06 10/0810/11 11/1211/15 12/1715-week Full Term (9/06 12/17): 103 days Our student in this example is enrolled for 6 credits in the full term and 3 credits in Part 1. Student did not enroll in Parts 2 and 3. She begins attendance in all three of her courses. Her period of enrollment is the entire term because she is enrolled in courses that span the entire term.

On September 14, she withdraws from both courses in the full term. She is still attending the course in Part 1 so there is no R2T4. Now, her enrollment period has changed. She has withdrawn from the full term courses before module 1 ends, so her period of enrollment ends with Part 1, on October 8. If she would complete the Part 1 course, there would be no R2T4. But she chooses to withdraw from it on September 24.

Lets look at the next slide.RSU Example 378Enrollment ends 9/24 with official withdrawalScheduled to attend until 10/08R2T4 requiredWithdrawal date is 09/24, 19 daysEnrollment period is 9/06 10/08, 33 days19/33 = .5757 = 57.6% Her enrollment ends with the official withdrawal on September 24. Her scheduled end date as of September 24 was the end of Part 1, October 8. So, the R2T4 looks at the enrollment period of Part 1, a total of 33 days. From September 6 through September 24 is 19 days. 19/ 33 = 57.6% attended.

If the student chose to withdraw from the full term courses after Part 1 ended, lets say on 10/09, her enrollment period for the R2T4 would be the entire term. It wouldnt matter that she completed the Part 1 course. At the point that she stopped attending, the end of Part 1, she was still enrolled for the full term courses. She would be a withdrawal for Title IV purposes.78RSU Example 4: Roommates799/06 begin attendance and complete 6 credits,Module 110/01 Zack withdraws,Module 210/11 Dave withdraws,Module 2 Not enrolled in Full Term; enrolled in Modules 1 and 2Neither student attends Module 2

15-week Full Term 103 days2 days2 daysModule 133 daysModule 233 daysModule 333 days 9/06 10/0810/11 11/1211/15 12/1715-week Full Term (9/06 12/17): 103 days In this term-based example, lets look at two different students, Zack and Dave, roommates. Both enroll for 6 credits in Part 1 and 6 credits in Part 2. Because they are not enrolled in any full term courses, and are not enrolled in Part 3, the period of enrollment is from September 6 to November 12.

Zack and Dave both begin attendance in their Part 1 courses. Zack decides at midterms that he really doesnt want to attend in Part 2. So, he withdraws from the 6 credits in Part 2 on October 1. Dave isnt really too excited about the Part 2 courses either, but he wants to think about them for awhile.

Because Zack withdrew from the Part 2 courses while still attending Part 1, his period of enrollment is now revised to end on October 8. Zack completes both of his Part 1 courses, and has attended through October 8. No R2T4 is required. Because he did not attend Part 2, you must return any Pell paid for those 6 credits.

Dave also completes his courses in Part 1, but he waits until the first day of Part 2 to visit the Registrar and withdraw from the Part 2 courses. That means that he withdraws on October 11. He never attends either of the courses in Part 2. Dave is a Title IV withdrawal.

We must do an R2T4 for Dave. At the point that he stopped attending, October 8, he was still enrolled for courses in Part 2. His period of enrollment went until November 12 and he did not complete those days. RSU Example 4: Roommates80ZackNo R2T4 required -- dropped Module 2 course before ceasing attendance in Module 1Pell recalculation required if paid for Module 2DaveR2T4 required since withdrew after ceasing attendanceWithdrawal date is 10/11, 36 daysEnrollment period is 9/06 11/12, 68 daysPell Recalculation if paid for Module 2 Withdrawing on October 11, that is 36 days of enrollment, from September 6. His enrollment period is 68 days, until November 12. 36 / 68 = 52.9%. RSU will have to return some of Daves Title IV. He may then owe RSU for his period of enrollment.

Notice the difference! Zack withdraws before he stops attending and his enrollment period is revised, no R2T4. Dave waits until after he stops attending to withdraw, and we must do an R2T4 and some of Daves aid will be returned.80