R2T4 – Return of Title IV Funds

1. R2T4 – Return of Title IV Funds VASFAA – May 2014 Laurie Owens, Director of Financial Aid

2. Agenda • Purpose • Process overview • Important deadlines • Modules • Best practices • Common audit findings • Performing hand calculations • Questions?

3. Purpose • Title IV funds are awarded based on the assumption that the student will attend school for the entire period. • When a student withdraws or stops attending, the student may no longer be eligible for the full amount of Title IV funds originally awarded. • The amount of Title IV grant and/or loan assistance earned by the student must be determined.

4. VCCS Impact • 23 colleges • Traditional and various dynamically dated sessions • # of R2T4s range from 4000-5000 per term for fall and spring; 1000-2000 per summer term • Modular regulations did not impact volume as expected

5. Process Overview • Identify the involved students • Complete the R2T4 Worksheet • Enrollment/payment period • Withdrawal date or LDA • Types of Title IV aid awarded/disbursed • Institutional charges • Breaks of 5 or more consecutive days • Return unearned aid or offer post withdrawal disbursement (PWD)

6. Identifying Students • Report or query in SIS • Last enrollment action is withdrawal as opposed to completion • 100% of aid earned if attend past 60% date • Return calculation still required to determine eligibility for PWD • Written confirmation of intent to return • Next course must start within 45 days of withdrawn course ending date • Custom page for intent to return

7. Intent to Return

8. Determining the Withdrawal Date • If required to take attendance... • Last date of academic attendance (LDA) as determined by attendance records • Must demonstrate participation in online courses (not just logging in) • If not required to take attendance or failure to earn any passing grades... • LDA if known or midpoint for enrollment or payment period • If withdrawn during break... • Last day of classes before break

9. Types of Title IV Aid • Unsubsidized Direct Loan • Subsidized Direct Loan • Federal Perkins Loan • Direct PLUS Loan • Federal Pell Grant • FSEOG • TEACH Grant • Iraq and Afghanistan Service Grant * Separate calc for VSFAP & GEARUP

10. Important Deadlines

11. Important Deadlines

12. Modules • Completion of at least one class previously exempted students from R2T4 • Regulation changed effective 7/1/11 • Students now subject to R2T4 if cease attendance at any point prior to completing the enrollment/payment period • Program is offered in modules if all courses do not span entire length of the enrollment/payment period • Summer impact

13. The 3 Questions 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 no, student is not a withdrawal. If yes, go to question 2. 2. When ceased to attend or failed to begin attendance in a scheduled course, was the student still attending other courses? If yes, student is not a withdrawal. If no, go to question 3. 3. Did the student confirm attendance in a later module in the enrollment period (starting within 45 days)? If yes, student is not a withdrawal as long as they return. If no, student is a withdrawal and R2T4 may apply.

14. Modules • Seek intent to return to later course starting within 45 days before processing R2T4 • Must recalculate aid for dropped or never attended courses prior to R2T4 • R2T4 required if last enrollment action is withdrawal not completion • Timing is key and results in inequities • Problem ED was attempting to resolve can still occur

15. Example 1 Enrollment PeriodLDA Class 1 08/22/13 - 12/19/13 09/28/13 Class 2 08/22/13 - 12/19/13 09/28/13 Class 3 08/22/13 - 12/19/13 09/28/13 Class 4 08/22/13 - 10/18/13 10/18/13 R2T4 Not Required: Student still attending modular course when withdrawn from traditional courses. Modular course subsequently completed. Last enrollment action is completion on 10/18/13.

16. Example 2 Enrollment PeriodLDA Class 1 08/22/13 - 12/19/13 10/20/13 Class 2 08/22/13 - 12/19/13 10/20/13 Class 3 08/22/13 - 12/19/13 10/20/13 Class 4 08/22/13 - 10/18/13 10/18/13 R2T4 Required: Student not attending other courses when withdrawn from traditional courses. Last enrollment action is withdrawal on 10/20/13. This student attends more days than the student in Example 1 and owes funds back simply due to timing of withdrawal.

17. Common Audit Findings • #3 on ED’s Top 10 Program Review Findings list • #2 and #3 on ED’s Top 10 Audit Findings list • Findings on both lists • R2T4 Returns Made Late • R2T4 Calculation Errors

18. Common Audit Findings • Problem: Returns not made within 45-day allowable timeframe • School’s policy and procedures not followed • Inadequate system in place to identify/track official and unofficial withdrawals • No system in place to track number of days remaining to return funds

19. Common Audit Findings • Solution: Returns not made within 45-day allowable timeframe • Review and revise policies and procedures to ensure funds are returned no later than 45 days after date of determination • Develop R2T4 monitoring/reporting system • Provide staff training • Periodically review processes, policies, and procedures to ensure compliance • Ensure timely communication between offices and/or systems • FSA Assessments

20. Common Audit Findings • Problem: R2T4 Calculation Errors • Incorrect number of days used in term/payment period • Actual clock-hours used instead of scheduled hours • Incorrect aid used as “could have been disbursed” • Incorrect withdrawal date • Mathematical and/or rounding errors

21. Common Audit Findings • Solution: R2T4 Calculation Errors • Work with academic offices to confirm when classes meet, including weekends • Exclude all class breaks of five consecutive days or more • Determine number of clock-hours student is scheduled to attend each day • Multiply the number of clock-hours scheduled each day by the number of scheduled days elapsed in the payment period or period of enrollment • Implement plan for peer review of each calculation • Conduct monthly self-assessment by reviewing random sample of student files

22. Things to Consider • Establishing the correct 60% date • Impact of unscheduled breaks resulting from inclement weather closings • Breaks between modules • Pell Recalculations • All term long • Census locking • Permissibility of less than half-time status after loan disbursement

23. Best Practices • Provide thorough R2T4 information on the on College’s website • Provide thorough R2T4 information with your award notifications • Post notices around campus (particularly in withdrawal locations) warning students about withdrawal implications • Educate Counseling and Student Records staff regarding withdrawal implications • Summarize withdrawal implications in your SAP policy literature • Consider having FAO sign off on withdrawals so students can be informed of impact

24. Best Practices - Faculty • Ensure there is a policy in place for students who never attend to be dropped or coded as such • Ensure there is a policy in place for students who stop attending to be withdrawn or coded as such • Ensure the last date of attendance is captured if required to take attendance • Ensure faculty do not award ‘W’ or ‘F’ grades to students who never attend • Ensure there is a policy in place to determine if failing grades are actually unofficial withdrawals • Communicate the necessity for accurate and timely reporting by faculty

25. Hand Calculations Programs measured in credit-hours: # of days in attendance = % of Title IV Earned # of days in the period Programs measured in clock-hours: # of scheduled clock-hours = % of Title IV Earned # of clock-hours in the period

26. Rounding • Percentages • Calculated to four decimal places • Rounded to three decimal places • 52/116 = .4482 to .448 to 44.8% • Exception: .6001 through .6004 which are not rounded for determining if past 60% point • Dollars and cents • Rounded to nearest penny: $977.207 to $977.21 • Repayment amounts can be rounded to the nearest dollar: $637.48 to $637

27. Hand Calculations • See handouts • 2014 Calendar • Calculating the Length of the Period • R2T4 Worksheet • Traditional 16 week term measured in credithours • Feel free to use cell phone calculators

28. Hand Calculations

29. Results Return of funds by the school? • Box O: $637.48 (rounded down to $637) To which Title IV program? • Subsidized Return of grant funds by the student? • $0 Repayment of the student’s loans? • $352.52 via terms of MPN • $353 due to rounding

30. Questions