return of title iv aid regulatory changes 34 cfr 668.22 final regulation published october 29, 2010...
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RETURN OF TITLE IV AIDRETURN OF TITLE IV AIDREGULATORY CHANGESREGULATORY CHANGES
34 CFR 668.2234 CFR 668.22Final Regulation Published Final Regulation Published October 29, 2010October 29, 2010
OASFAADublin, OHMay 24, 2011
R2T4 – Current Definitions 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
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R2T4 – Current Definitions 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
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““Offered in Modules”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
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““Offered in Modules” - Example AOffered 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)
““Offered in Modules” - ExampleOffered in Modules” - ExampleAA
Jeff Enrolls in all three summer sessions and ceases enrollment on Day 5 in the first
5-week session
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““Offered in Modules” - ExampleOffered in Modules” - ExampleAAThe 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” - ExampleOffered in Modules” - ExampleAA
Session 15 weeks
Session 25 weeks
Session 35 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” - ExampleOffered in Modules” - ExampleBB
Summer sessions include three 5-week sessions and 15-week sessions
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““Offered in Modules” - ExampleOffered in Modules” - ExampleBB
Session5- week
Session5-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” - ExampleOffered in Modules” - ExampleBB
Session5- week
Session5-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
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Theory Behind the CalculationTheory Behind the CalculationStudent earns Title IV aid through
attendance◦Percentage of aid earned is equal to the percentage of payment period or enrollment period completed
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Return Of Title IV FundsReturn Of Title IV FundsApplies 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
returnedto the programs
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How Does It Work?How Does It Work?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 Effective Date Of New RegulationsRegulationsApplies to all students who withdraw
from payment period or period of enrollment that begins on/after July 1, 2011
DOES NOT APPLY TO CROSSOVER DOES NOT APPLY TO CROSSOVER PAYMENT PERIODS IN 2011PAYMENT PERIODS IN 2011
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Program DefinitionsProgram DefinitionsNew 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
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Credit Hour Programs Credit Hour Programs Offered In ModulesOffered In ModulesStandard 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
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Credit Hour Programs Credit Hour Programs Offered In ModulesOffered 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
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Credit Hour Programs Credit Hour Programs Offered In ModulesOffered In Modules
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 program19
Credit Hour Programs Credit Hour Programs Offered In ModulesOffered 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
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Clock Hour ProgramsClock 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
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Is Student A Withdrawal?1. 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
2. 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
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
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Return After WithdrawalReturn After WithdrawalModular 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 withdrawalClock 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
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R2T4 Calendar Days R2T4 Calendar Days Modular ProgramsModular Programs
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
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After Written Confirmation After Written Confirmation Of ReturnOf ReturnStudent 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
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R2T4 & Taking AttendanceR2T4 & Taking AttendanceR2T4 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
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Required To Take AttendanceRequired To Take AttendanceSchool 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
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Required To Take Required To Take AttendanceAttendanceIf 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
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AttendanceAttendanceAttendance 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 subject29
Questions????Questions????
Jamie A. Malone
Training Officer
U.S. Department of Education
312-730-1528
What did she say????
I was thinking.
.
Hmm
m
…
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Please provide any comments Please provide any comments to my supervisor-to my supervisor-
Jo Ann BorelTitle IV Training [email protected]
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