# Presentation: 370357

## Principles of Title IV “Aid That Could Have Been Disbursed”

- Lesson 3

## Objectives

- Understand the impact of:
- 30-day delayed disbursements
- Late disbursements
- Inadvertent Overpayments
- Verification not completed before withdrawal

**Notes:**
Change first bullet to, “Identify new fields and understand the use of Prior Year Import”.

## Aid That Could Have Been Disbursed (ATCHBD)

- Conditions for Late Disbursement in 34 CFR 668.164(g)(2) must be met at time student withdrew
- Include all undisbursed Title IV aid for the period for which you perform the return calculation
- Include as ATCHBD, even if disbursement was prohibited
- May not disburse

## Conditions for Late Disbursement

- All Title IV Aid (Except PLUS)
- Department processed a SAR or ISIR with an official EFC for the student

## Conditions for Late Disbursement (continued)	

- FSEOG:
- the institution made the award to the student;
- FFEL or Direct Loan:
- the institution certified or originated the loan, as applicable; and
- Federal Perkins Loan
- the institution made the award to the student

## Effect of Aid That Could Have Been Disbursed

- Increases amount of aid earned
- Decreases amount of aid to be returned
- Eligibility for a post-withdrawal disbursement could increase

## 30-Day Delayed Disbursement

- If first-year first-time student withdraws before 30 days *and*
- Meets late disbursement requirements
- Net amount of loan can be used as ATCHBD
- No portion of the loan can be disbursed

## Return of Title IV Aid Verification Rules

- Schools must perform R2T4 calculation within 30 days of the date of determination of withdrawal
- Return interim disbursements
- Include PLUS and unsubsidized loans in the calculation
- Perform a new R2T4 calculation if verification is completed later

## Determining Which Funds to Include

- If all required documents _are received_ before R2T4 calculation, include:
- Pell Grant, FSEOG, Perkins Loan, subsidized or unsubsidized Stafford or Direct Loans, and PLUS loans
- If all required documents _are not received_ before R2T4 calculation, include:
- PLUS and unsubsidized Stafford and Direct Loans

## Determining Which Funds to Include (continued)

- If all required documents _are received_ before the verification deadline, include:
- Perform a new R2T4 calculation
- Include: Pell Grant, FSEOG, Perkins Loan, subsidized and unsubsidized Stafford or Direct Loans, PLUS loans

## Inadvertent Overpayments & R2T4

- School may hold inadvertent overpayment while it determines if student is entitled to a post-withdrawal disbursement (PWD) under R2T4
- Prevents returning funds needed later for PWD
- If entitled to PWD, student may only receive the earned portion of the inadvertent overpayment

## Activity	

- Individual Activities
- 	Participant Workbook page 3-7

## Text: Scenarios 1 and 2: Thirty-Day Delay

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## Scenario 1: 30-Day Delay

- Include $1000 loan as “aid that could have been disbursed” (ATCHBD)
- No portion can be released as post-withdrawal disbursement
- All funds must be returned
- 30-day delay would have prohibited disbursement on withdrawal

## Scenario 2: No 30-Day Delay

- Include $1000 loan as ATCHBD
- If eligible, a portion can be released as post-withdrawal disbursement
- Unearned portion must be returned

## Text: Scenarios 3 and 4: Late Disbursement

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## Scenario 3: Late Disbursement

- Include 1st $990 as “aid that was disbursed” (ATWD)
- Include 2nd $990 as ATCHBD
- No post-withdrawal disbursement available
- Could not have made disbursement  because late disbursement criteria not met

## Scenario 4: Late Disbursement

- Include 1st $990 as ATWD
- Include 2nd $990 as ATCHBD
- Cannot disburse 2nd or subsequent disbursement as post-withdrawal disbursement because student did not complete the enrollment period

## Text: Scenarios 5 and 6 :

*[Live Meeting Editable Text. Use ****Live Meeting**** > ****Edit Slide Properties...**** to edit.]*

## Scenario 5: Verification Not Completed Before Withdrawal

- List Pell and FSEOG as aid that could have been disbursed.
- School completes the verification process.
- Perform the R2T4 calculation; and
- Include the Pell Grant and FSEOG as aid that could have been disbursed.

## Scenario 6: Verification Not Completed Before Withdrawal

- Perform the R2T4 calculation including the $4050 PLUS loan as aid that was disbursed.
-  When the student provides the missing signature and qualifies for a Pell Grant, do a second R2T4 calculation, including the $550 Pell Grant as aid that could have been disbursed.

## Business Process Worksheet

- Review BPW Step 5
- Determine aid that could have been disbursed