Transcript Slide 1

RETURN OF TITLE IV AID
REGULATORY CHANGES
34 CFR 668.22
Final Regulation Published
October 29, 2010
OASFAA
Dublin, OH
May 24, 2011
R2T4 – Current Definitions

Standard Terms
◦ Semesters, trimesters – generally 14–17 weeks long
◦ Quarters – generally 10–12 weeks long

Non-standard terms – where all coursework is expected to
begin and end within a set period of time that is not a semester,
trimester, or quarter terms

Non-terms – all clock hour programs and credit hour programs
that do not begin and end within a set time (self-paced), where
courses overlap, where sequential courses do not begin, and
end within a term
2
R2T4 – Current Definitions

“Week of instructional time”
◦ Any seven consecutive day period with at least one day
in which scheduled instruction or examination occurs
◦ Does not include homework time, vacation time,
orientation, or counseling
3
“Offered in Modules”

If the student ceases attendance before the period for
which aid was awarded, it is a withdrawal

The denominator of the return calculation includes the
full number of weeks used to determine the aid award,
absent any institutionally scheduled breaks of five or
more consecutive days or periods of time that the
student was on an approved LOA
4
“Offered in Modules” - Example A

Institution A:
◦ Fall and Spring = standard terms
 Never considered to be “offered in modules”
◦ Summer = three 5-week sessions (combined to be a standard
term)
 Students can enroll in any of the summer sessions or all of them
 Students enrolled in the 5-week summer sessions are considered in
programs “offered in modules” since none of the sessions span the entire
length of the term (the 15-week period)
5
“Offered in Modules” - Example A
 Jeff
Enrolls in all three summer sessions and
ceases enrollment on Day 5 in the first
5-week session
6
“Offered in Modules” - Example A

The Results:
◦ Step 1 – Recalculate Pell & Campus-based
◦ Step 2 – Determine earned & unearned amounts
of Title IV aid (TIV)
 Numerator = # of days attended in Course 1
(assume no breaks) 5 days
 Denominator = Start date of Course 1 thru
end date of Course 3 (less any scheduled break
of 5 or more consecutive days or approved
LOAs) 105 days or .048 or 4.8%
“Offered in Modules” - Example A
Session 1
5 weeks
Session 2
5 weeks
Session 3
5 weeks
35 days
35 days
35 days
Withdrawal Day 5 student also drops remaining sessions.
Institution Required to Take Attendance: WD = Day 5. Denominator =
105 days. Per GEN 04-12, the institution must have a process to
make this determination no later than 14 days after the LDA.
Institution not Required to Take Attendance: WD = 668.22(c).
Denominator = 105 days.
“Offered in Modules” - Example B

Summer sessions include three 5-week sessions and
15-week sessions
9
“Offered in Modules” - Example B
Session
5- week
Session
5-week
Session
5-week
Session 15- week
LuGail enrolls in two 15-week courses – this student is not
considered to be enrolled in a program offered in modules.
.
“Offered in Modules” - Example B
Session
5- week
Session
5-week
Session
5-week
Session 15- week
Scott enrolls in one 5-week module and one 15-week course. H is considered
to be enrolled in a program offered in modules.
Scott
Theory Behind the Calculation

12
Student earns Title IV aid through
attendance
◦ Percentage of aid earned is equal to the
percentage of payment period or
enrollment period completed
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
◦ All Title IV aid disbursed must be returned
to the programs

13
How Does It Work?
14

If 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
Effective Date Of New Regulations

Applies to all students who withdraw from
payment period or period of enrollment that
begins on/after July 1, 2011

DOES NOT APPLY TO CROSSOVER
PAYMENT PERIODS IN 2011
15
Program Definitions
New rules define a program “offered in
modules”
◦ A course or courses in program do not
span entire length of payment period or
period of enrollment
 Doesn’t matter what “modules” are called
at the institution

16
Credit Hour Programs
Offered In Modules

17
Standard term program “offered in modules”
◦ Two 8-week sessions within a 16 week
semester
◦ Three 5-week sessions within a 15 week
semester
◦ Two 6-week sessions within a 12 week
quarter
◦ Winter “inter-session” or “J term” between
fall and spring semesters
Credit Hour Programs
Offered In Modules
• Student considered to be withdrawal if
does not complete all days scheduled to
complete within payment period/term
• School must document completed all
courses with a passing grade
• If no passing grade in last scheduled course,
school must demonstrate student
completed period
18
Credit Hour Programs
Offered In Modules

19
Student in modular program not considered a
withdrawal if
◦ Provides written confirmation of intent to
attend a future module in period of enrollment
 Must be provided at the time of withdrawal
◦ Student may change return date in writing
 Must provide change prior to original return
date
• Future module must begin within 45 calendar
days in a non-standard and non-term program
Credit Hour Programs
Offered In Modules

Nonstandard & Nonterm Programs
◦ Student 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
20
Clock Hour Programs
• Student considered to be withdrawal if
does not complete all clock hours and
weeks of instructional time that was
scheduled to complete
• School must document completed all
courses with a passing grade
• If no passing grade in last scheduled course,
school must demonstrate student
completed period
21
Is Student A Withdrawal?
1.
2.
3.
Did the student cease to attend before completing or fail to
begin attendance in a course scheduled to attend?
 If yes, go to question 2.
 If no, student 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 not a withdrawal
 If 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 withdrawal.
 If not a withdrawal, Pell recalculations may apply
22
22
Return After Withdrawal
Modular term-based credit hour program
◦ Withdrawn student may return to same
program prior to end of payment period/period
of enrollment
 Student eligible for any Title IV funds for which
eligible prior to withdrawal
 Clock hour/nonterm credit hour program
◦ Withdrawn student may return to same
program within 180 calendar days
 Student eligible for any Title IV funds for which
eligible prior to withdrawal

23
R2T4 Calendar Days
Modular Programs


24
Total calendar days include all days on which the
student was scheduled to attend
◦ Days of completed courses count if course does not
span length of term
◦ Exclude scheduled breaks of at least 5 consecutive
days when student not scheduled to attend a
module or other course offered during that period
For a withdrawn student who has made schedule
changes
◦ Do not count days of courses officially dropped
prior to complete cessation of attendance
After Written Confirmation
Of Return
Student considered to be withdrawal if
does not return as scheduled
 Withdrawal dates back to time that
confirmation originally provided
◦ Determine withdrawal date and days of
attendance as if confirmation of future
attendance never provided

25
R2T4 & Taking Attendance
R2T4 calculates Title IV aid earned based
upon student attendance
◦ Aid prorated based upon days or hours
student attended
 Should use best information available to
determine withdrawal date since it directly
impacts dollars

26
Required To Take Attendance

27
School is required to take attendance if
◦ Outside entity requires that attendance
be taken OR
◦ School has own requirement that
instructors take attendance OR
◦ Outside entity or school has
requirement that can only be met by
taking attendance or a comparable
process
Required To Take Attendance

28
If required to take attendance—
◦ For some students—use attendance
records for those students
◦ For a limited period of time—use
attendance records for withdrawals
during that limited period of time
◦ On a specific date—NOT considered to
be required to take attendance
Attendance

29
Attendance must be “academic attendance” or
“attendance at an academically-related activity”.
Examples include
◦ Physical class attendance where there is direct
interaction between instructor and student
◦ Submission of an academic assignment
◦ Examination, interactive tutorial, or computer-assisted
instruction
◦ Study group assigned by school
◦ Participation in on-line discussion about academic
matters
◦ Initiation of contact with instructor to ask question
about academic subject
Questions????
What did she
say????
I was
thinking.
.
Jamie A. Malone
Training Officer
U.S. Department of
Education
312-730-1528
[email protected]
30
Please provide any comments
to my supervisorJo Ann Borel
Title IV Training Supervisor
[email protected]
202-377-3930
31