R2T4: Implementing Adjustments Required by HERA and CCRAA

1. R2T4: Implementing Adjustments Required by HERA and CCRAA

2. We Will Discuss • Determining Withdrawal Date • HERA and CCRAA Changes to R2T4 • R2T4 Examples • Deadlines • Resources • Applying R2T4 to Modular Programs and Summer Sessions

3. Determining Withdrawal Date

4. When Does R2T4 Apply? • When a Title IV grant or loan recipient withdraws from ALL classes or leaves school before end of payment period (pp) or period of enrollment (poe) • R2T4 also applies to a student who withdraws and whose parent borrowed a PLUS loan

5. When a Student Withdraws, the School Must: • Establish the student’s withdrawal date • Document date when school determined that the student withdrew • Maintain documentation for four years

6. Schools Required to Take Attendance by Outside Entity • A student’s withdrawal date is the last day of his or her attendance • If student is absent 14 consecutive days, the school is expected to determine whether the student intends to return to class or to withdraw

7. Schools Not Required to Take Attendance Must: • Make known their official withdrawal requirements • Identify the procedures for an official withdrawal • Designate at least one office that can be readily contacted by a student to initiate withdrawal

8. Schools Not Required to Take Attendance • For student who officially withdraws, the withdrawal date is the earlier of: • The date the student began the official withdrawal process, or • The date the student otherwise notified the school of his or her intent to withdraw. • NOTE: School may on a case-by-case basis use the last day the student participated in an educationally related activity as the withdrawal date

9. Schools Not Required to Take Attendance • The withdrawal date for a student who drops out without notification is: • The midpoint of the pp or poe, or • At the school’s option, the last documented date of an academically related activity which may be before or after the midpoint.

10. HERA and CCRAA Changes to R2T4

11. Worksheet Changes • Use worksheets from current FSAH or R2T4 on the Web • ACG, SMART, Grad PLUS and TEACH added to redesigned worksheets • ‘Other Title IV Aid’ which included LEAP, SLEAP, SSS and Gear Up has been deleted from R2T4 consideration • Revised worksheets available at ifap.ed.gov under “Worksheets, Schedules and Tables”

12. HERA Changes: Software • Department of Education software for withdrawals on or after 7/1/06 is not available. • R2T4 on the Web is available at: fafsa.ed.gov/FOTWWebApp/faa/faa.jsp

13. HERA Changes: Overpayments • Student is no longer responsible for grant overpayment of $50 or less • Student’s grant overpayment amount substantially reduced: reduce initial overpayment amount by 50% of the total of all grants that have been disbursed or could have been disbursed.

14. HERA & CCRAA Changes: PWD • Student’s authorization required to: • Apply PWD grants to outstanding charges other than tuition, fees, room, board and prior year charges of $200 or less • Apply PWD loans to outstanding charges* • Disburse PWD loans directly to student* *Parent’s authorization required in the case of a parent PLUS loan.

15. HERA & CCRAA Changes: PWD • Notification to student (or parent in case of PLUS) of availability of PWD must: • Include source, type and amount of grant or loan funds • Include notice that funds may be accepted, a partial amount accepted, or rejected • Include explanation of obligation to repay loan • Include deadline for student/parent response • Be retained together with response.

16. HERA Changes: Other • School has 45 days after the date it determines student has withdrawn to return funds • Multiple leave of absences are permitted • Scheduled clock hours are used exclusively to determine earned aid

17. R2T4 Examples

18. Deadlines

19. Deadlines Triggered by “Date of School’s Determination That Student Withdrew” • 30 days for school to: • Perform the R2T4 calculation • Notify student of grant overpayment • Notify student of eligibility for a post-withdrawal disbursement (pwd) loan • 45 days for school to return Title IV funds • 45 days to disburse pwd grants • 180 days to disburse pwd loan funds to student or parent

20. Resources

21. Resources • 2008-09 Federal Student Aid Handbook (FSAH), pages 5-23 to 5-175. • FSAH available on ifap.ed.gov under “Publications”

22. Resources • Helpful tables and forms in 08-09 FSAH: • 5-114 Withdrawal dates for a school that is not required to take attendance • 5-117 R2T4 Requirements and Deadlines • 5-125 Information required when referring student overpayments to Borrower Services

23. Applying R2T4 to Modular Programs and Summer Sessions

24. Modular Programs; Example 1 • Assume that a standard term consists of two consecutive sessions, A and B. Session A Session B /_______________/_______________/ Enrolled Not Enrolled

25. Modular Programs; Example 2 • Assume that a standard term consists of two consecutive sessions, A and B. Session A Session B /________________/________________/ Not Enrolled Enrolled

26. Modular Programs; Example 3 • Assume that a standard term consists of two consecutive sessions, A and B. Session A Session B /________________/________________/ Enrolled Enrolled

27. Any questions or comments? Ed Schroeder eschroeder@glhec.org