nasfaa u authorized event: 2017–18 return of title iv ... · nasfaa u authorized event return of...

2017-18AUTHORIZED EVENTS

CREDENTIALEDTRAINING

RETURN OF TITLE IV FUNDS

Slide Handout

© 2010–2017 by National Association of Student Financial Aid Administrators (NASFAA). All rights reserved. NASFAA has prepared this document for use only by personnel, licensees, and members. The information contained herein is protected by copyright. No part of this document may be reproduced, translated, or transmitted in any form or by any means, electronically or mechanically, without prior written permission from NASFAA. NASFAA SHALL NOT BE LIABLE FOR TECHNICAL OR EDITORIAL ERRORS OR OMISSIONS CONTAINED HEREIN; NOR FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES RESULTING FROM THE FURNISHING, PERFORMANCE, OR USE OF THIS MATERIAL. This publication contains material related to the federal student aid programs under Title IV of the Higher Education Act and/or Title VII or Title VIII of the Public Health Service Act. While we believe that the information contained herein is accurate and factual, this publication has not been reviewed or approved by the U.S. Department of Education, the Department of Health and Human Services, or the Department of the Interior. The Free Application for Federal Student Aid (FAFSA®) is a registered trademark of the U.S. Department of Education. NASFAA reserves the right to revise this document and/or change product features or specifications without advance notice. April 2017

NASFAA U Authorized EventReturn of Title IV Funds

© 2017 NASFAA 1

Slide 1 © 2017 NASFAA

National Association of Student Financial Aid Administrators


Return of Title IV Funds

A NASFAA Authorized Event

2017-18


Lesson 1:Introduction to Return of Title IV Funds


Key Concepts

Withdrawal

• Student ceased attendance in all classes during payment period/period of enrollment

Title IV Recipient

• Received federal grant or loan funds

• Meets the requirements to receive a late disbursement of federal loan funds

Title IV Aid

• Certain federal financial aid programs subject to R2T4


© 2017 NASFAA 2


Return of Title IV Funds Formula

Earned Aid• Disbursed or undisbursed federal funds the student

may keep

Post-Withdrawal Disbursement• Undisbursed federal funds the student earned and

could receive

Unearned Aid• Disbursed federal funds for which the student doesn’t

qualify


Institutional Refund Policies

• Amount of unearned Title IV aid to return is independent of school’s refund policy

• Title IV regulations do not govern school’s refund policy


When R2T4 Requirements Apply

Credit-hour Clock-hour

Nonterm and Nonstandard

termModule


© 2017 NASFAA 3


When R2T4 Requirements Don’t Apply

SituationPerform R2T4

Calculation

School Returns Funds

Student Returns Funds

Partial withdrawal No No No

Did not establish Title IV eligibility No No No

Deceased student Yes Yes No



Quick Quiz:1. Define “Title IV recipient.”2. Which Title IV programs are not subject to the return of

Title IV funds requirements?

3. Define “unearned aid.”4. When is a student considered to have withdrawn from a

credit-hour program?

5. Name two situations for which the return of Title IV funds requirements do not apply.


© 2017 NASFAA 4


• What do you think the rationale is for the R2T4 requirements?

• What challenges might you have explaining R2T4 requirements to students?


Learning Activity: Determining if the Return of Title IV Funds Requirements Apply

Page 7


Learning Activity: Do the R2T4 Requirements Apply?1. Marco is enrolled for four classes at Roman University.

His financial aid for the term consists of a Federal Pell Grant, FSEOG, and a Direct Subsidized Loan. During the third week of the term, he drops all of his classes because he wants to transfer to a school closer to home. Yes No

Page 7


© 2017 NASFAA 5


Learning Activity: Do the R2T4 Requirements Apply?2. Natalie is registered for five classes at Zion State

University. Her financial aid for the term consists of a Direct Subsidized Loan and Federal Work-Study (FWS). She drops her calculus class after the first exam because the class is much harder than she expected. Yes No


Learning Activity: Do the R2T4 Requirements Apply?3. Fina is studying sculpting at the Fine Arts Institute. She is

registered for three classes for the fall semester. Her financial aid for the term consists of a state grant and a scholarship from the Sculptors Benevolence Fund. She drops all of her classes the second week because she broke her right arm and won’t be able to participate in her classes while her arm is in a cast. Yes No

Page 7


Lesson 2:Determining the Withdrawal Date


© 2017 NASFAA 6


Required to Take Attendance

• A school is required to take attendance if:– Requirement imposed by outside entity– Voluntarily takes attendance– Required by the program

• Includes taking attendance for:– A limited period of time– Certain populations


Academic Attendance

Includes

• Physically attending class

• Submitting an academic assignment

• Attending a study group assigned by the school

• Participating in an academic online discussion

• Academic questions to course faculty

Does not include

• Living in institutional housing

• Using school meal plan• Participating in student-

organized group• Logging into an online

course without active participation

• Participating in academic counseling or advising


Not Required to Take Attendance

• Withdrawal date depends on whether the student is an:– Official withdrawal– Unofficial withdrawal


© 2017 NASFAA 7


Unofficial Withdrawals

• Occurs when a student drops out without notifying the school

• Schools have a choice:– Midpoint of the payment period– Last date of attendance in an academically

related activity that is earlier• Timeframe for determination



• Should all schools be required to take attendance in order to establish a withdrawal date for return of Title IV funds purposes? Why? Why not?

• Which office/individual on your campus would be the most appropriate to return Title IV funds and to perform R2T4 calculations? Why?*

• Should multiple offices be responsible for R2T4-related functions? Which offices would perform which functions and why?*

Page 17

* Compare your responses once you complete the Learning Activity on page 18.


© 2017 NASFAA 8


Withdrawal from Programs Offered in Modules• Course does not span the entire payment

period• A withdrawal occurs when student:

– Ceases attendance before completion of payment period as scheduled, AND

– No written confirmation of future attendance provided


Example: Mitch and Brandy

Semester(14 weeks)

Module 1(7 weeks)

Module 2(7 weeks)

Mitch• Enrolled in:

– 14-week semester– Modules 1 and 2

• Considered enrolled in a program with modules

Brandy• Enrolled in:

– 14-week semester (three courses)

• Not considered enrolled in a program with modules


Written Confirmation of Future Attendance

Paper or electronic format

Student may change date under certain circumstances

Nonterm and non-standard term requirements


© 2017 NASFAA 9



Example: Elsa

• Enrolled in 15-week semester• Ceases attending classes on Day 20 of first

module• Does not provide written confirmation

Module 1 (3 credits)



Without written confirmation, R2T4 is requiredDAY 20



© 2017 NASFAA 10


Quick Quiz 2:1. Harry is enrolled in a program that offers courses in a

modular format, as well as courses that span the entire term. Each one of Harry’s courses covers the 18-week trimester. Is his program offered in modules? Yes, the program is offered in modules No, the program is not offered in modules

2. What are the three questions a financial aid administrator should ask when determining if a student has withdrawn from a program offered in modules?

Page 21


Learning Activity: Exercise—Ineda Goodwon

Page 22



Review the scenarios described on page 22. Using the schedule below, and the decision tree, “Determining Whether or Not a Student Has Withdrawn From a Program Offered in Modules,” on page 30, determine the answers to the questions for each scenario.

Quarter 1

Record your answers on page 22.

Page 22


© 2017 NASFAA 11



Page 22

Is Ineda enrolled in a program offered in modules? Yes No

Is Ineda considered a withdrawal in this scenario? Yes No

Is the school required to perform a R2T4 calculation? Yes No

Scenario A: Ineda attends Module 1 and then ceases attending Module 2 after completing just three days. She does not confirm attendance in a later module, and she does not attend Modules 3 and 4.



Page 22

Is Ineda considered a withdrawal in this scenario? Yes No

Is the school required to perform a R2T4 calculation? Yes No

Is R2T4 required if she confirms, but does not begin attendance in the third and fourth modules?

Yes No

Scenario B: Ineda attends Module 1 and then ceases attending Module 2 after completing just three days. At that time, she provides written confirmation that she still intends to attend Modules 3 and 4, as originally planned.


Learning Activity: Interview

Page 23


© 2017 NASFAA 12


Learning Activity: Interview1. Does your institution have programs offered in modules?

Which ones?2. If your institution has modular programs, what challenges

have been encountered in relation to return of Title IV funds processing and calculations?

3. If your institution has modular programs, what is the student’s process for confirming attendance in a future module upon deciding to withdraw from a current module?

Page 23


Student is Unable to Begin Withdrawal Process

• Circumstances beyond the student’s control may prevent official withdrawal

• May use date the circumstance occurred, if school is not required to take attendance


Rescinding Official Withdrawal Notice

If rescinding notice, it must:

• Be in writing• Indicate student will

finish payment period or period of enrollment

Subsequently withdraws,

withdrawal date is:

• First notification of his intent

• Date began process• Last date of an

academically-related activity


© 2017 NASFAA 13


Fails to Earn a Passing Grade in Any Course• Applies to schools not required to take

attendance• Must be able to determine if student actually

completed payment period• Considered an unofficial withdrawal if:

– Fails to earn a passing grade in any course– Cannot document requirements for one course

completed


Leave of Absence

• A temporary interruption of student’s studies• Does not include:

– Nonattendance during a scheduled break– Situations addressed by incomplete courses

• Formal policy not required– If formal policy exists, must meet regulatory

requirements



© 2017 NASFAA 14



Page 29


Learning Activity: Interview1. Does your school have a formal, written leave of absence

(LOA) policy? If so, how does it compare to the requirements of a Title IV approved LOA?

2. If a student notifies the school that she is withdrawing or begins the school’s official withdrawal process, but later decides not to withdraw, the student may rescind the withdrawal. How is this accomplished at your school?

3. How does your school determine that a student, who receives a failing grade in all of his courses for an enrollment period, actually completed that period? Describe the process.

Page 29


Lesson 3:Return of Title IV Funds Formula


© 2017 NASFAA 15


Determine the Percentage ofPeriod Completed

• Title IV aid is earned based on percentage of period completed

• Calculation of percentage completed is the only difference between credit-hour and clock-hour programs

Step 1

Earned a portion of aid Earned all aid

60% 100%


Credit-hour % Completed

Days attendedDays in period

Clock-hour % Completed

Scheduled hours at withdrawal

Hours in period


Step 1



• Nonterm credit-hour programs– Last day may depend on individual student

program progression– Number of days in payment period depends on

whether or not the program is self-paced

Step 1


© 2017 NASFAA 16



• Modular programs– Only include completed days in numerator– Include only the number of days the student

was scheduled to attend in the denominator– Exclude days from denominator under certain

circumstances

Step 1


Learning Activity: Determine the Percentage Earned

Page 40



Review the scenarios described on pages 40-41. Using the calendars for 2017 and 2018 on pages 42-43, determine the percentage of period completed for each student.

Record your answers on pages 40-41.

Pages 40-41


© 2017 NASFAA 17



Page 40

Chrystal, a Title IV aid recipient, enrolls for 15 credit hours spring semester. The dates of the spring semester are 1/2/18 through 5/1/18. The semester includes a spring break that begins February 24 and ends March 4; classes resume March 5. In January, Chrystal missed two weeks of classes due to illness. Feeling over-whelmed by all the coursework she must make up, she officially withdraws on 1/26/18.

Percentage completed?



Page 40

Logan, a Title IV aid recipient, enrolls for 12 credit hours fall semester. The dates of the fall semester are 8/21/17 through 12/1/17, with a break between 11/22 and 11/26; classes resume 11/27. On 9/8, Logan stopped going to classes. He did not tell the school he withdrew or moved out. On 1/3/18, the school determined Logan left during the fall, after beginning attendance, and sets his withdrawal date at the midpoint of the semester, 10/8.




Page 40

Magdalene, a Title IV aid recipient, began a 900 clock-hour program on 1/2/18. On 2/16/18 (her last day of attendance), Magdalene withdrew to take a job in another state. She completed 150 clock hours. She was scheduled to complete 200 clock hours during her first payment period, which consisted of 450 clock hours.



© 2017 NASFAA 18



Page 41

Anthony, a Title IV aid recipient, enrolls for six credit hours during the 8-week summer session. The summer session (6/4-7/27/18) contains two modules that are 4 weeks each, without scheduled breaks of five days or longer. The first module is 6/4-6/29/18. The second module is 7/2-7/27/18. Anthony enrolled in 3 credits in the first module and 3 credit hours in the second. He withdrew from all classes on 6/22/18, without written confirmation of future attendance.



Determine the Amount of EarnedAid

Total aid x %

completed = Earned aid

Step 2


Disbursed Aid versus Aid That Could Have Been Disbursed

• Both used in the R2T4 calculation as a snapshot of student eligibility

• Modules– Must recalculate eligibility for the Federal Pell

Grant and campus-based funds– Do not recalculate eligibility for Direct Loans

• Aid that could have been disbursed consists of undisbursed aid the student is eligible for


© 2017 NASFAA 19


Learning Activity: Calculating Earned Aid

Page 46


Learning Activity: Calculating Earned AidFor the case study of “Ahmed” described on page 46, use the information provided to determine this student’s earned aid, for the purposes of the return of Title IV funds calculation.

You have all the information you need on page 46. You also may choose to use the blank R2T4 Worksheet (Steps 1 and 3) on page 56.

Page 46



Page 46


© 2017 NASFAA 20



Page 46



Page 46



© 2017 NASFAA 21


Quick Quiz 1:1. Why is including aid that could have been disbursed a

benefit to the student when doing a return of Title IV funds calculation?

2. What is the institution’s responsibility once it has determined a student has withdrawn?

3. What is the rounding rule when calculating earned aid?

Page 47


Determine the Amount ofUnearned Aid

Disbursed aid – Earned

aid = Unearned aid

Step 3


Determine the School andStudent Shares

• School’s share– Lesser of the total amount of unearned aid or

amount equal to institutional charges multiplied by percentage earned

• Student’s share– Difference between unearned aid and the

school’s share

Step 4


© 2017 NASFAA 22


Allocate Unearned AidStep 5

Federal Loans

• Direct Unsubsidized

• Direct Subsidized

• Federal Perkins Loan

• Federal PLUS

Federal Grants

• Federal Pell Grant

• FSEOG• TEACH Grant• IASG


Learning Activity: Allocating Unearned Aid

Page 50


Learning Activity: Allocating Unearned AidFor the case study of “Sophia” described on page 50, use the information provided to determine this student’s earned aid, for the purposes of the return of Title IV funds calculation.

You have all the information you need on page 50. You also may choose to use the blank R2T4 Worksheet (Steps 1, 3, 4, and 6-10) on pages 56-57.

Page 50


© 2017 NASFAA 25



Quick Quiz 2:1. What is the equation to figure out how much of a student’s

aid is unearned?2. What is the order (of programs) in which aid is returned?

3. What is the de minimis Title IV grant amount for a student?

Page 51


Returning Unearned Aid

School • 45 days from date of determination

Student or Parent

• Loan funds are repaid according to promissory note

Student • Grant fund repayment options


© 2017 NASFAA 26


Other Considerations

• Use of payment period or period of enrollment

• Prorating institutional charges• Treatment of Title IV Credit Balances• Date of determination



• Why do you think return of Title IV funds calculations are necessary?

• Is your institution one that requires attendance be taken? What do you think the benefits may be to students if a school takes attendance?

Page 55


© 2017 NASFAA 27


Lesson 4:Post-Withdrawal Disbursements and Timeframes


Title IV Funds Formula: Earned Aid Exceeds Disbursed Aid

Determine the Percentage of Period Completed

Determine the Amount of Earned Aid

Determine the Amount of the Post-Withdrawal Disbursement

Step 1

Step 2

Step 3


Title IV Funds Which Cannot Be Included

Title IV Grants

Direct Loans

Federal Perkins Loans


© 2017 NASFAA 28



Quick Quiz 1:1. As a benefit to the student, what is also considered along

with disbursed aid when calculating earned aid? Post-withdrawal disbursements Aid that could have been disbursed Aid that the school can never disburse

2. For clock-hour programs, only _____________ hours are used in the calculation.

3. What Title IV loans cannot be included in a post-withdrawal disbursement?

4. What is the institution’s responsibility in regard to post-withdrawal disbursements?

Page 72


Credit Unpaid Charges

• Crediting student account– May credit grant funds– May not loan funds without borrower

confirmation• Requirements

– Disbursement notification– Authorization requirements– Other cash management restrictions

Step 4


© 2017 NASFAA 29


Offering Any Portion NotCredited to Institutional Charges

• School must directly disburse to the student any amount of a post-withdrawal disbursement of grant funds not credited to the student’s account

• Requirements– Disbursement notification

Step 5



• Why do you think the regulations give schools the flexibility to allow students to have the post-withdrawal disbursement after the original deadline set by the school? Do you agree or disagree with the regulations?

• How are post-withdrawal disbursement notices forwarded to the student and/or the parent borrower? Is it done via postal mail, email, or by some other means? Why does your institution use this method and in what ways is it effective? Are there ways that your school may tweak its notification process?

Page 76


© 2017 NASFAA 30


Timeframes

• Notifications• Aid student must repay • School’s return of funds• Post-withdrawal disbursements• Verification



Quick Quiz 2:1. The mix of ________________ and _________________

aid cannot be altered after a student has withdrawn.2. What charges can be covered by a post-withdrawal

disbursement without student or parent PLUS borrower approval? Current award year charges for tuition Current award year charges for fees Prior year charges $200 or less for tuition, fees, room

or board All of the above

Page 79


© 2017 NASFAA 31


Quick Quiz 2:3. A notification offering a post-withdrawal disbursement

should include a _____________ that the borrower wants the Title IV funds.

4. How long does a student have to pay a Title IV grant overpayment? 45 days 30 days 180 days 240 days

Page 79



Page 78


Learning Activity: Interview1. Is your school subject to the 30-day delayed disbursement for

first-year, first-time borrowers? Does this affect your post-withdrawal disbursements? How?

2. How does your school handle students who have an outstanding balance and may be eligible for a post-withdrawal disbursement, but have not submitted all documentation for verification? Do you reach out to these students? Do the students continue to receive notifications to submit documents for verification?

3. May students set up a payment plan for satisfying overpayments directly with the school or must that process be handled with ED?

Page 80

NOTES:

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

_______________________________________________________________

1801 PENNSYLVANIA AVENUE NW, SUITE 850WASHINGTON, DC 20006

202.785.0453 FAX. 202.785.1487 WWW.NASFAA.ORG

© 2017 National Association of Student Financial Aid Administrators

The National Association of Student Financial Aid Administrators (NASFAA)

provides professionaldevelopment for financial

aid administrators; advocates for public policies that increase

student access and success;serves as a forum on student financial aid issues; and is

committed to diversitythroughout all activities.

nasfaa u authorized event: 2017–18 return of title iv ... · nasfaa u authorized event return of...

Documents