David A. Bartlett
Federal Student Aid
U.S. Department of Education
MASFAP Spring 2013
Return to Title IV
Return of Title IV Funds
Applies only to Title IV eligible students who begin attendance and then completely withdraw, or otherwise cease attending
If student enrolled but never attended any classes:
Student did not establish eligibility for any funds Student did not establish eligibility for any funds
All Title IV aid disbursed must be returned to the programs
All Title IV aid disbursed must be returned to the programs
Theory of the Calculation
• Percentage of aid earned is equal to the percentage of payment period or enrollment period completed • If school has disbursed more aid
than the student has earned, money is returned to the programs, or
• If school has disbursed less aid than the student has earned, a post-withdrawal disbursement will be calculated and if applicable funds disbursed to the student
Institutional Refund Policy
•Your institutional refund policy has no
impact on the Return of Title IV funds
calculation
•
Student still earns Title IV Aid for period
attended even if school removes the
charged tuition and fees
•
R2T4 calculation supersedes your
institutional refund policy
Consumer Information
•School must provide to prospective students and current students
•Any refund policy with which the school must comply
•School’s tuition refund policy
•Requirements of treatment of Title IV funds after withdrawal
•Procedures for official withdrawal
R2T4 Calculation Timeframes
• Institutions are required to returnfunds to the applicable program within 45 days of the date of determination
• Institutions are required to notify a student of the need for
authorization to make a Post-Withdrawal Disbursement (PWD) of Title IV loan funds within 30 days of the date of determination (DOD).
• FSA Handbook Volume 5
Rounding Rules
Dollar Amounts and Percentages
Calculation -round 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 Calculate out to 4 decimal places • 45 days / 101 days = .4455 • 199 hours / 450 hours = .4422 Round to third decimal place • .4455 = .446 = 44.6% • .4422 = .442 = 44.2%
Payment Period or Period of Enrollment
Standard term-based program must use payment period
• May choose on a program-by-program basis • Must be consistent with application of
method used
• Use consistently for each category of students who withdraw from same program of study and
• Attended from the beginning • Re-enter during period • Transfer into school during period
Nonstandard term or nonterm program may choose either payment period or period of enrollment
Complete Top of Worksheet First
HARRY SPRINGER
1 26 1 26
Aid That Could Have Been Disbursed
(ATCHBD)
Student met conditions for a late disbursement (668.164(g)(2)) –
•At time student withdrew, ED had processed a SAR or ISIR with official EFC
•Pell – ISIR with eligible EFC
•DL – loan had been originated
•Promissory Note must be signed to be included as ATCHBD* •TEACH – grant had been originated
•Perkins/FSEOG – funds had been awarded
•Perkins Loan – Promissory Note must be signed to be included as ATCHBD*
* The Promissory Note must be signed prior to the R2T4 Calculation being completed as described in GEN-05-16
Step 1
Title IV Aid Information
DL Second/Subsequent Disbursements
•Include as aid that
could have been
disbursed if student
met the “conditions
for a late
disbursement”
Date of Institution’s Determination
that Student Withdrew
•Schools required to take attendance should have a DOD no later than 14 calendar days after student’s last date of attendance
•When did the school know of the student’s withdrawal?
•If unofficial withdrawal, determine withdrawal date no later than 30 days after the end of the earlier of the
1. Payment period / period of enrollment, or
2. Academic year, or
3. Educational program
Step
2
Withdrawal Date –
School Not Required to Take Attendance
•Use the earlier of
•date student began school’s withdrawal process; or
•date student otherwise provided “official” notice; or
•midpoint in period (if student didn’t notify school); or
•if student didn’t notify due to circumstances beyond student’s control, the date related to that circumstance; or
•Date school determines leave began (if student didn’t return from approved leave of absence), or
•Use the last date of attendance at an academically related activity as documented by the school
•Written policy, publicized to students
•Student followed school’s policy and was approved
•The leave does not involve additional charges
•LOA may not include more than 180 days in any 12-month period
•Must be a reasonable expectation of return
•Student allowed to complete coursework begun prior to leave at the same point they left
§34 CFR 668.22(d)
Approved Leave
July 1, 2011 Regulatory Change
•If the institution requires faculty to take attendance in certain circumstances, then the institution is considered “required to take attendance”, for example:
•School requires faculty to take attendance for all of a particular major, then for that major any student that withdraws from the school would be considered “required to take attendance” •School requires faculty to take attendance
during the add/drop period, then school is considered “required to take attendance” during add/drop period Ju ly 1, 201 1
•Institutions not required to take attendance
Regulatory Change: Credit Hour Program with Modules
•A program is “offered in modules” if a course or courses in the program do not span the entire length of the payment period or period of enrollment
•Student may provide intent to attend a future module in writing
•R2T4 calculation not required if the student attends future module
•Future module must begin within 45 calendar days in a standard or non-term program Jul y 1, 201 1
•Modules are defined in 668.22(l)(6)
Regulatory Change: R2T4 Calculation
•Non-Standard terms not substantially equal in length and student has Pell and Loans
•Possible that student(s) withdraw during overlapping payment periods
•Standard terms with modules
IF… school is required to take attendance by outside entity (such as state or accrediting agency)
THEN... withdrawal date is taken from attendance records
NOTE: Requirement might apply only to specific groups of students
Step 2
Withdrawal Date –
School Required to Take Attendance
Counting Calendar Days or Scheduled Clock Hours
Count every day, including weekends and
holidays, except:
•
Scheduled break of five or more
consecutive days when no classes are
offered
•
Days of leave of absence are not included
in total days
•
Special rule for schools that offer
coursework in modules
Clock Hour Calculation
• Scheduled hours per day times number of days of scheduled class from first day of payment period/period of enrollment to last date of attendance 6 hrs X 9 Days = 54 Numerator is clock
hours scheduled to be completed as of the student’s last date of attendance
• Payment Period = 450 clock hrs. Denominator is clock
hours scheduled to be completed in the payment period/period of enrollment
• School must complete R2T4 calculation in clock hours
New regulation July 1, 2011 for program measured/reported to state/accrediting body in clock hours
Step 2 - Clock Hour
54.00 450 12 0
12 0 1 17
Step 3
Amount of Title IV Aid Earned by Student
Post-Withdrawal Disbursements (PWD)
•When Title IV aid disbursed is less than Title IV aid earned
•Step 4, Box J on R2T4 Worksheet
•Must be made from available grant funds before available loan funds
•Funds that could have been disbursed
PWD of Loan Funds: Notifications & Confirmations
•Schools Must:
•Notify a student, or parent (parent PLUS loan), in writing prior to making any PWD
•Receive confirmation from the student or parent borrower prior to disbursement
•Provide written notification within 30 days of date of determination of withdrawal
•Identifying type and amount of funds
•Explaining options to accept or decline some or all of funds
•Obligation to repay any loan funds disbursed
•Provide a deadline for response
Post-Withdrawal Disbursement
of Grant Funds
No student confirmation required to credit student’s account
Disbursed as credit to account – within 180 days after date of determination
Step 4 (cont.)
Step 5
Amount of
Unearned
Title IV Aid
Due from the
School
Books and Supplies
Institutional Charges
• Title IV funds provided under assumption that they are used to pay institutional charges ahead of all other aid
• Are always charges assessed for entire payment period or period of enrollment prior to withdrawal
Institutional Charges
• Include tuition, fees, room and board (if contracted with school) and other educationally-related expenses assessed • For nonterm, credit hour programs use costs
associated with number of courses student is expected to complete in period for which aid is awarded
– If student withdraws, institutional charges must include all courses student was initially expected to complete
Institutional Charges –
When to Prorate: 34 CFR 668.22(g)(3)
For nonterm-based programs where return calculation based on payment period but school charges for period of enrollment
• Institutional charges for payment period are prorated down from longer period
If school has retained Title IV in excess of prorated amount, including allocating costs for equipment and supplies to the beginning of the program, funds retained are attributed to that payment period
Step 5
Step 6
Return of Funds by School
•
Law specifies order of Title IV
programs to which funds must be
returned
•
Never return more money than was
received from a Title IV program
Return of Funds by School
•
Return funds to program(s) as soon
as possible, but no later than 45
calendar days after the date of
determination of withdrawal
•
Calculation must be completed
within 30 calendar days of the date
of determination of withdrawal
Step 7
Return of Funds by Student
1000.00
Step 8
Repayment of Student’s Loans
Repayment of Student’s Loans
•
Student is responsible to repay any
loan funds not returned by the
school
Step 9
Calculating Grant Overpayment - Example
3,200
215.25 0 215 25
215.25 1,600 -1384 75
1,600 00
Step 10
Return of Funds by Student
•Law specifies order of Title IV programs
to which funds must be returned
•
Student is obligated to return any Title
IV overpayment in the same order that
is required for schools
Grant Overpayment and Notifications
•Within 30 days of determining that a
student who withdrew must repay all or
part of a Title IV grant, school must
provide notification that:
•
student owes an overpayment
•
eligibility for Title IV funds will end after
45 day period
•
student must repay using one of the
positive action steps
Positive Action Steps
to Retain Eligibility
Student retains Title IV eligibility for 45 days
• During that time, student must either:
• repay in full to school
• make satisfactory arrangements to repay
with school (school’s option-not required)
• make satisfactory arrangements to repay
with Department of Education
Receipt of Additional TIV Funds During the 45-day Period of Extended Eligibility
If student fails to return the overpayment or comply with action steps:
• student becomes ineligible for Title IV funds following 45 day period
• funds received during this period do not have to be returned unless student withdrew
R2T4 Reporting Processes for Grant
Overpayments
•
For payments received on a
current-year overpayment make appropriate
COD entry
•
For payments received on previous
year’s grants, make same entry in
COD, and electronic refund function
in G5
R2T4 Reporting Processes for Direct
Loan Program: Payments and Reductions
If student has received an overpayment of
Direct Loan funds
• school should reduce student’s award/disbursements by making a downward adjustment in COD
• school then returns funds to the Department using the Electronic Refund function in G5
Reporting Overpayments to NSLDS
A school may report an overpayment to NSLDS
• any time after student has had the opportunity to pay off overpayment in full to the school, OR • indicate their intent to negotiate
repayment arrangements with Debt Resolution Services
Referring overpayments for collection vs. reporting overpayments to NSLDS • referring is the process of turning over a
student’s debt to Debt Resolution Services • reporting is the process of creating within
NSLDS a record of a student’s overpayment.
Referring Overpayments
to the Department
Resources
•FSA Handbook, Volume 5
•34 CFR 668.22
•Program Integrity Information – Questions and Answers
http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/return.html •Preamble to the Final Regulations 10/29/2010
http://www.gpo.gov/fdsys/pkg/FR-2010-10-29/pdf/2010-26531.pdf •GEN -11-14 July 20, 2011: Implementation of Program
Integrity Regulations
•FSA Coach
http://www2.ed.gov/offices/OSFAP/fsacoach/index.html
Additional Resources
•Dear Colleague Letter GEN-04-03 (February 2004)
•Dear Colleague Letter GEN-04-12 (November 2004)
•R2T4 Demo Site available at
•http://fafsademo.test.ed.gov
•R2T4 website available via FAA Access to CPS Online
•http://www.faaaccess.ed.gov/
•FSA Assessments
QUESTIONS?
David Bartlett U.S. Department of Education Federal Student Aid 816‐268‐0434 david.bartlett@ed.govPresentation Evaluation
I would appreciate if you would take the time to submit an evaluation of this presentation. A paper evaluation
is attached. Thanks much!