Return of Title IV Funds — Programs with Modules or Compressed Courses

Overview

These new regulations aim to provide for more consistent and equitable treatment of students who withdraw from a program measured in credit hours, regardless of whether courses in the program span the entire term or consist of shorter modules. Students in the following programs will be impacted:

The effective date for these changes is July 1, 2011

Program Integrity Principles:

  • Title IV funds are awarded to a student to attend an entire payment period or period of enrollment, and the funds are intended to cover the student’s educational and living expenses for the entire period.
  • The law specifies that a student earns Title IV funds on a pro rata basis through 60 percent of a period based on the ACTUAL days completed.Documenting Attendance: For the purposes of federal financial aid programs, we must be able to document your active participation in an academic activity. It DOES NOT INCLUDE:
    • Logging into an online course without active participation in discussions, etc.
    • Academic Counseling
    • Using the universiy meal plan or living in institutional housing

Regulatory Requirements:

A student is considered to have withdrawn from a payment period or period of enrollment in which the student began enrollment if the student ceased attendance in all scheduled courses without completing:

  • All of the days the student was scheduled to complete in the period, in a credit-hour program

    However, if a student provides written confirmation to a school — at the time of ceasing attendance that the student plans to attend another course later in the same period, the student is not considered to have withdrawn from a standard-term program.

    For a nonstandard-term or nonterm program, the next course the student plans to attend during the period must begin within 45 days after the end of the course the student ceased or failed to attend, in order for the student not to be considered withdrawn.

    If a student does not resume attendance within the scheduled timeframe, the student is considered to have withdrawn as of the date on which attendance ceased.

    If a student does not provide written confirmation of plans to return to school later in the same period, a school should consider the student to have withdrawn and performs a return of Title IV funds (R2T4) calculation to determine if any funds must be returned. However, if the student does return to school in the same period — even if the student did not provide written confirmation of plans to do so — the student is not considered to have withdrawn after all and is eligible to receive Title IV funds for which the student was eligible before ceasing attendance.

    A school must reverse the R2T4 process and provide any additional funds the student is eligible to receive at the time of return.

    The new rule replaces prior guidance provided in Dear Colleague Letter GEN-00-24 regarding student withdrawals in term-based programs that include courses shorter than the length of an entire term.

    The rule impacts all programs offering courses shorter than an entire term, including semester-based programs with a summer term consisting of two, consecutive six-week summer sessions.

Thanks to the Texas Guaranteed Student Loan Corporation for most of the content of this page.

Updated July 8, 2011