# Presentation: 664046

## Tribal Colleges:  The Basics Return of Title IV FundsR2T4

**Deborah Tarpley**
- Department of Education, Region VIII

***Session #45***

- Session 45 - Tribal Colleges:  The Basics

##      Myth 

- “You must do a Return of Title IV Funds calculation for _**every student**_** that doesn’t complete your payment period.”**

- Session 45 - Tribal Colleges:  The Basics

## Truth #1

**	****A Return of Title IV Funds calculation is done only for students who **_***actually attended***_** school and therefore **_***established eligibility for Title IV funds***__*.*_

- Session 45 - Tribal Colleges:  The Basics

## Truth #2

- 	If a student didn’t attend, they are not eligible for ***any*** Title IV funds
- No R2T4 calculation required
- Return it ***ALL***

- Session 45 - Tribal Colleges:  The Basics

## Remember

**You must *****always***** have a way of knowing whether the student actually attended classes in order to be eligible for any Title IV funds.**

- Session 45 - Tribal Colleges:  The Basics

## How does the calculation work?

**How does the ****calculation work?**

- Percentage of aid
- earned

- Percentage of period completed

**Student earns Title IV aid **
**through attendance**

**=**

- Session 45 - Tribal Colleges:  The Basics

## How does the calculation  work?

- If student has ***received*** ***more*** money than he has earned, money is returned to the programs
- If student has ***received less ***money than he has earned, a post withdrawal disbursement must be calculated

- Session 45 - Tribal Colleges:  The Basics

## Consumer Information

- Must provide to prospective and current students:
- Any refund policy with which school must comply
- School’s tuition refund policy
- Requirements for treatment of Title IV funds after withdrawal (page 2-175)
- Procedures for official withdrawal

- Session 45 - Tribal Colleges:  The Basics

## Date of Institution’s Determination that Student Withdrew

***When did the school realize that the student had withdrawn?  ***
- If not official withdrawal, determine withdrawal date no later than 30 days after the end of the earlier of the . . .
- Payment period or period of enrollment
- Academic year
- Educational program

- Session 45 - Tribal Colleges:  The Basics

## Date of Institution’s Determination that Student Withdrew 

**Other important deadlines key off this date**:
- 30 days for school to return funds it’s responsible for returning
- 30 days to offer post withdrawal disbursement
- 120 days to disburse the post withdrawal disbursement
- 30 days to notify student if overpayment is due
- 2 years for school to collect overpayment

- Session 45 - Tribal Colleges:  The Basics

## Payment Period or   Period of Enrollment

- Standard term-based program must use term/payment period
- Non-standard term or non-term program may choose either payment period or period of enrollment

- Session 45 - Tribal Colleges:  The Basics

## Rounding Rules for    Percentages

- Calculate out to 4 decimal places
- 45 days / 101 days = .4455
- 199 hours / 450 hours = .4422
- Round to third decimal place
- .4455 = .446 = 44.6%
- .4422 = .442 = 44.2%

- Session 45 - Tribal Colleges:  The Basics

## Rounding Rules for Dollar Amounts

- Round to the nearest penny
- $2,346.00 x 44.6% = $1,046.316 or $1,046.32
- $2,346.00 x 44.4% = $1,041.624 or $1,041.62
- Disbursement or refund may be rounded to the nearest dollar
- $1,046.32 = $1,046
- $1,041.62 = $1,042

- Session 45 - Tribal Colleges:  The Basics

## Step 1:  Student’s Title IV Aid Information

- Title IV aid disbursed
- Title IV aid that could have been disbursed
- Do not include FWS earnings
- Tribal Colleges will always include 100% of the FSEOG amount in the calculation (Title III waiver)

- Session 45 - Tribal Colleges:  The Basics

## Aid That Could Have Been Disbursed

**School has official ISIR/SAR**
**FFEL - loan is certified **
**DL - loan is originated **
**Pell Grant - valid ISIR/SAR**
**Perkins/FSEOG - funds were **
**	****awarded**

- Session 45 - Tribal Colleges:  The Basics

## FFEL/DL Second/Subsequent Disbursements

- Include as could have been disbursed aid if loan was certified
- Cannot actually be paid in a post-withdrawal disbursement
- 668.164(g)(2)(ii)(a) and (B)

- Session 45 - Tribal Colleges:  The Basics

## Amount Disbursed

- Pell Grant    $1,519

- FSEOG  $250

- Session 45 - Tribal Colleges:  The Basics

## Box A

**$1,769**

- Session 45 - Tribal Colleges:  The Basics

## Box B

**$1,769**

- Session 45 - Tribal Colleges:  The Basics

## STEP 2:Withdrawal Date - School that Is Required to Take Attendance

**IF**... school is required to take attendance
- By outside entity for some part of the period of enrollment
**Then...** withdrawal date is taken from attendance records
- Requirement might apply only to specific groups of students

- Session 45 - Tribal Colleges:  The Basics

## Withdrawal Date- School that Is Not Required to Take Attendance 

- Use
- Earlier of date student began school’s withdrawal process or date student otherwise provided “official” notice; **Or**
- If student didn’t notify school, midpoint in period; **Or**
- If student didn’t notify due to circumstances beyond student’s control, date related to that circumstance; **Or**

- Session 45 - Tribal Colleges:  The Basics

## Withdrawal Date - School that is Not Required to Take Attendance 

**If student didn’t return from approved leave of absence**
- date school determines leave began; **Or **
**If student took unapproved leave of absence**
- date student began leave

- Session 45 - Tribal Colleges:  The Basics

## Withdrawal Date - School that is Not Required to Take Attendance

- School not required to take attendance always has option of using the date of student’s last attendance at school documented academically-related activity

- Session 45 - Tribal Colleges:  The Basics

## Optional Approved Leave of Absence Policy

- Written policy publicized to students
- Student followed school’s policy and was approved
- The leave does not involve additional charges
- Student allowed to complete coursework began prior to leave
- LOA may not include more than 180 days in any 12-month period

- Session 45 - Tribal Colleges:  The Basics

## Step 2:  Calendar Days for Credit Hour Programs

- Count every day, including weekends and
- holidays, except:
- Scheduled break of five or more consecutive days when no classes are offered
- Days of leave of absence are not included in total days

- Session 45 - Tribal Colleges:  The Basics

## Step 2:  Calendar Days for Credit Hour Programs

**64**

**108**

**59.3**

**=**

- Session 45 - Tribal Colleges:  The Basics

## Myth

- 	**“****If you don’t disburse any aid to students until they have passed the 60% point of the semester, you don’t have to do a Return of Title IV funds calculation.”**

- Session 45 - Tribal Colleges:  The Basics

## Truth

- When a student who was eligible for Title IV funds ceases to attend, *at any point in the semester*, a Return of Title IV Funds must be calculated.
- A student is considered to have  “earned” all of the aid he was eligible for once he passes the 60% point in the semester.

- Session 45 - Tribal Colleges:  The Basics

## Step 3:  Amount of Title IV Aid Earned by Student

**59.3%**

**$1,769**

**$1,049.02**

**=**

**X**

- Session 45 - Tribal Colleges:  The Basics

## Step 4: Total Title IV Aid to be Disbursed or Returned

- Determine if post-withdrawal disbursement or return of funds is required
- Compare Title IV aid earned (D) with
- 	Title IV aid actually disbursed (A)
- D = A  no further action
- D > A  post-withdrawal disbursement
- A > D  return of funds

- Session 45 - Tribal Colleges:  The Basics

## Step 4: Total Title IV Aid to be Returned

- 	**Title IV aid disbursed****	****             (A)**
**Amount of Title IV aid earned    ****	****(D)**
**Total Title IV aid to be returned****	**** (F)**
**	****	****$1,769.00 - $1,049.02 = $719.98**

- Session 45 - Tribal Colleges:  The Basics

## Step 5:  Amount of Unearned Title IV Aid Due from School

**Total Institutional Charges  $2,250**
**Determine % unearned  **
**	****	****	****100.0%**
**	****	****	**_**- 59.3% earned**_
**	****	****      ****=  40.7% unearned**

- Session 45 - Tribal Colleges:  The Basics

## Step 5:  Amount To Be Returned By School

**Institutional Charges  X  % unearned**
**  ****	****	****$2,250  x  40.7% = $915.75**
**Then compare Box I and Box F**
**Return the lesser amount, write in Box J**
**	****	****$915.75  vs.  $719.98**

- Session 45 - Tribal Colleges:  The Basics

## Step 6:  Return of Funds by School 

**Law specifies order of Title IV programs to which funds must be returned**
**Never return more money than was received from a Title IV program**

- Session 45 - Tribal Colleges:  The Basics

## Step 6:  Return of Funds by School

- Return funds to programs as soon as possible, but no later than 30 days after determination of withdrawal

- Session 45 - Tribal Colleges:  The Basics

## Step 7:  Initial Amount of Unearned Title IV Aid Due from Student

**	****$719.98  (Box F amount to return)**
_**-  $719.98**_**  (Box J amount due from school)**
**         ****0**
**This is initial amount due back from student.  **

- Session 45 - Tribal Colleges:  The Basics

## Step 8:  Return of Funds by Student

**Law specifies order of Title IV programs to which funds must be returned**
**Loans are repaid in accordance with terms of promissory note**
**Grant repayment limited to 50% of student’s initial responsibility to repay**

- Session 45 - Tribal Colleges:  The Basics

## Step 8:  Student’s Grant Overpayment

**Step 8:  Student’s Grant Overpayment**

**Initial amount**
**to be returned **
** ****to Grant**

**50%**

**Amount for Student to Return**

- X

**=**

**X**

**=**

- Session 45 - Tribal Colleges:  The Basics

## Grant Overpayment

**Any grant repayment due from student is considered an overpayment**
**Occurs because student has received more aid than he earned by attending**
**Student is responsible for repayment **
**Amounts under $25 are set aside**

- Session 45 - Tribal Colleges:  The Basics

## Grant Overpayments

**School must notify student within 30 days of school’s determination of withdrawal**
**Student retains Title IV eligibility for 45 days.  During that time, he must either:**
**Repay in full to school**
**Make satisfactory arrangements to repay with school (school option)**
**Make satisfactory arrangements to repay with Department of Education**

- Session 45 - Tribal Colleges:  The Basics

## Referring Overpayments to the Department 

**If student does not repay in full or make payment arrangements with school within 45 days, school must refer overpayment to Department for collection.**
**Referral form can be found in the FSA Handbook, Volume 2, Page 226**

- Session 45 - Tribal Colleges:  The Basics

## Report Overpayment to NSLDS

**Overpayments not paid in full within 45 days of the institution’s determination of the withdrawal must be reported to NSLDS**
**Reported via on-line process**

- Session 45 - Tribal Colleges:  The Basics

## Post-Withdrawal Disbursements

**When Title IV aid disbursed is less than Title IV aid earned **
**Mighty’s Ledger #2**
**Step 4 Box E**
**   ****$1,049.02 (Box D)**
**      **_**–       **__**0      (Box A)**_
**	****= $1,049.02**

- Session 45 - Tribal Colleges:  The Basics

## Post-Withdrawal Disbursement Tracking Sheet

**School must make disbursement **
**Within 120 days of school’s determination of withdrawal**
**From grants before loans**
**May credit student’s account for outstanding charges prior to release of funds to student **

- Session 45 - Tribal Colleges:  The Basics

## Post-Withdrawal Disbursements

**School must offer any additional disbursement to student in writing**
**Within 30 days of school’s determination of withdrawal**
**Identify type and amount of funds**
**Provide option to accept/decline all or part within 14 days of notice**

- Session 45 - Tribal Colleges:  The Basics

## Additional Resources

**Dear Colleague Letter GEN-00-24 December 2000**
**R2T4  Software available at **_**http://fsa4schools.ed.gov**_
**Click on SAIG Software Download**

- Session 45 - Tribal Colleges:  The Basics