Compliance Concerns: R2T42013 Spring Conference

WASFAA Federal Issues CommitteeSusan Johnson, UW-WhitewaterKristina Klemens, UW-ParksideJulie Waldvogel-Leitner, Moraine Park Technical College

Topics R2T4 Regulation Resources Basic calculation Common terms Modules Discussion

R2T4 Regulation Resources Section 484B of the HEA

Enacted October 7, 1998, as part of the Higher Education Amendments of 1998

Final Reg published November 1, 1999 Dear Colleague Letter GEN-00-24 Final Reg published November 1, 2002 Dear Colleague Letter GEN-04-03 Dear Colleague Letter GEN-04-12 Dear Colleague Letter GEN-05-16 Final Reg published October 29,2010 Dear Colleague Letter GEN-11-14 IFAP – Program Integrity Q’s & A’s – Return of Title IV Funds FSA Handbook, Volume 5

Basic calculationTotal # of days completed

Total # of days scheduled to complete

% aid earned X Total aid disbursed and aid that could have been disbursed

Total aid – Earned aid

Institutional charges X Unearned %

= % of aid earned

= Earned aidIf greater than disb aid, student elig for post-withdrawal disbursement

= Unearned aid

= Amount for school to return

Basic calculation, cont’dUnearned aid – Amount school returns

Total loans – Loans school must disbursed return

Amount student – Loans student

must return must repay

Total grants X 50%

Initial amt of grants – Grant protection

= Amount student returns

= Loans student must repay

= Initial amount of unearned grants

= Grant protection

= Grants student must return

Clock hour schools In a clock hour program, a student is

considered to be a withdrawal if she/he does not complete all scheduled clock hours and weeks of instructional time.

For calculation: Numerator is clock hours scheduled to be

completed as of the student’s LDA Denominator is clock hours scheduled to be

completed in payment period/period of enrollment.

Payment Period/Period of Enrollment Payment Period: A school-defined length of time for

which financial aid funds are paid to a student. For programs using academic terms (semester, trimester, or quarter), a payment period is equal to a term. For programs not using academic terms, schools must designate at least two payment periods within an academic year that meets all applicable regulations.

Period of Enrollment: The period for which a Stafford or PLUS loan is intended. Except at nonterm schools, the period of enrollment must coincide with a bona fide academic term established by the school for which institutional charges are generally assessed (e.g, semester, trimester, quarter, length of the student’s program or academic year). Also referred to as the loan period.

Withdrawal Date Withdrawal Date: The date the student

withdraws, as determined by the school.

Date of determination: The date the institution became aware the student withdrew.

Required to Take Attendance School is required to take attendance by outside

entity (i.e., accrediting agency) School itself has a requirement instructors take

attendance The school or the outside entity have a

requirement that can only be met by taking attendance

May apply to a subset of students (i.e., students in a particular program)

May apply for only a short period of time

Academically Related ActivityInclude, but are not limited to:

Physically attending a class Submitting an assignment Taking an exam Attending an assigned study group Participating in an online discussion Initiating contact with a faculty member to discuss the

subject

Optional for the school to use Must be documented by the school (not the student)

Aid That Could Have Been DisbursedIf conditions for a late disbursement were met before the student withdrew, include as aid that could have been disbursed

All Student Aid (including Pell) - ED processed SAR/ISIR with official (not necessarily a valid) EFC

Direct Loan – Institution originated the loan Perkins/FSEOG - Institution made the award

Do not include a loan if the promissory note has not been signed at the time you complete the calculation

Institutional Charges All charges for tuition and fees Room and board, if contracted with the school Expenses for required course materials if the

student does not have a real and reasonable opportunity to purchase elsewhere

Do not include discretionary expenses – parking, library fines, health services, etc.

Modules Any course which does not span the length of the

payment period or period of enrollment Even if student is attending full term courses,

they are considered to be in a program offered in modules if at least one course does not span the entire payment period

Example: 12 week term, could take combination of courses

3 weeks 3 weeks 3 weeks 3 weeks

12 week course

How to determine if a student enrolled in module courses has withdrawn

1. 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 an swer is yes, go to question 2.

2. When the student ceased to attend or failed to be gin 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; however other regulatory provisions concerning recalculation may apply. If the answer is no, go to question 3. 

3. Did the student confirm attendance in a course in a module beginning later in the period (for nonterm and nonstandard term programs, this must be no later than 45 calendar days after the end of the module the student ceased attending)? 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 and the Return of Title IV Funds re quirements apply.

R2T4 Modules Example 1Winter is considered a “module” of spring for FA purposes.

Winter is from January 7th-February 2nd

Spring is from February 4th-May 17th

Spring Break is March 24-31st

4 weeks 15 weeks (spring)

19 week total award period

R2T4 Modules Example 1Student enrolled for 3 credits for winter, 12 for spring and was awarded full time eligibility.

Winter grade posted after spring started, student received “FN” grade indicating unofficial withdraw

To determine if an R2T4 was required, I: Contacted professor’s for spring.

Student was attending for spring, therefore no R2T4 required

No aid adjustment was required because student was still full time

R2T4 Modules Example 1Shortly after contacting the professors, the student fully withdrew for spring

An R2T4 was required. To correctly calculate, I: Contacted professor for winter to determine

how long the student attended Determined how many days student attended

for spring Determined total days of award period

R2T4 Modules Example 1Student attended:

7 days for winter + 10 days for spring 17 total days

Award Period was: 130 total days - 8 day spring break 122 total days

Total # of days completed =17 days

# of days scheduled to complete =122 days=13.9% earned

R2T4 Modules Example 2Summer Term consists of 12 weeks, with multiple modules (3 week, 6 week, 9 week, or full term courses).

Student enrolled in 2nd 3 week and 3rd 3 week:3W, Module 2: June 18 – July 63W, Module 3: July 9 – July 27

Student completed Module 2 and dropped Module 3 on July 6. Does this require R2T4?

R2T4 Modules Example 2Yes! When a student withdraws and completes on the same day, R2T4 is required.

Total # of days completed = 19 days

# of days scheduled to complete = 40 days

Earned aid is 47.5%

One more thing to consider. . .

R2T4 Modules Example 2Student’s aid:Pell Grant: $1387 (half time)Unsub: $2006 (net $1996)

Student did not begin attendance in all classes, so recalculate Pell first. Pell: $694 (less than half time)Unsub: $1996Total Aid: $2690 X 47.5% = $1277.75 earned

R2T4 Modules Example 3 Summer term is 12 weeks, consists of

multiple enrollment options. Student enrolled in 3 4-week module

courses Mod 1: May 20-June 21 Mod 2: June 24-July 19 Mod 3: July 22-August 16

4 week 4 week 4 week

Total: 12 Week Summer Term

R2T4 Modules Example 3 Student total enrollment was 9 credits, 3

per 4 week mod course On June 15th, student DROPPED course

from mod 2 (June 24-July 19th), but did NOT drop a course from mod 3.

Is an R2T4 required?

Dropped Mod 2 on 6/15 5/20-6/21 6/24-7/19 7/22-8/16

R2T4 Modules Example 3 To find out, we:

Contacted the student Are you attending mod 1? –YES Are you going to be attending mod 3? –YES

No R2T4 required because student is maintaining enrollment, but still must adjust aid

R2T4 Modules Example 3 Student award:

Pell-$2081 Unsub-$2,000

Since student is now ½ time instead of ¾ time, reduced Pell to $1,387

No revision to loan eligiblity