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- Program Integrity Q&A -

In addition to the following Q&As, please see the following resources for guidance related to Retaking Coursework:
                - Preamble to the final regulations ( https://www.govinfo.gov/content/pkg/FR-2010-10-29/pdf/2010-26531.pdf ) – published 10/29/2010

RC-Q1: If a student receives an F in a course, how many times can a student receive aid to retake that course?

RC-A1: You may include any repetition of the program in a student's enrollment status for a term as long as the student has never passed the course.  If the student passes the course, you may include one repetition after passing the course.  Any second or subsequent repetition of the passed course may not be included in the student's enrollment status for purposes of the title IV, HEA, programs. [Guidance issued 8/26/2011]

RC-Q2: If a student gets an F the first time he or she takes a course and subsequently passes the course with a D, how many times can the student receive title IV funds to improve their D grade?

RC-A2: Only once. [Guidance issued 8/26/2011]

RC-Q3: A music student must participate in a specified number of years in band or orchestra.  The student auditions with other students to be picked, and the selected students play in that ensemble for the entire year.  The course number stays the same from semester to semester but the content, in this example, the music performed, changes each term.  Does the fact that the course number does not change result in a student being considered to be retaking course work, and therefore ineligible for aid?

RC-A3: The example provided deals with a program where all students are expected to enroll in a class on a continuing basis, and the recurring use of the same course number -- but not the same course content -- would not be considered to be retaking coursework.   Course numbering is not determinative, as that numbering is established for the administrative convenience of the institution.

However, simply changing the syllabus for a course that is offered every term would not mean that students can receive aid repeatedly for the same course.  The treatment described above for the specific example of participation in a band or orchestra would not be applicable where a student was retaking an individual class, regardless of whether the syllabus for the class was changed.  [Guidance issued 8/26/2011]

RC-Q4: A graduate student must complete a dissertation writing course each term of enrollment.  Is this subject to the restriction on repeating courses?

RC-A4: Yes. The new regulations related to retaking coursework apply to the definition of full-time for undergraduate and graduate students. [Guidance issued April 28, 2016]

RC-A5:  If a student withdraws from all Title IV eligible courses in the payment period or period of enrollment, and continues to attend only the course(s) that he or she is completing or repeating for which he or she may not receive Title IV aid during that period, the student is a withdrawal for Title IV purposes.

This is because a student is considered to be attending a Title IV eligible program only if they are attending one or more courses in that program for which the student is receiving Title IV, HEA program funds.  Therefore, a student who ceased attendance in all of the Title IV eligible courses is considered to be no longer attending a Title IV eligible program and is a withdrawal for Title IV purposes, regardless of any continued attendance in courses for which the student may not receive Title IV, HEA program funds during that period.

For example, a student enrolls in four courses in the spring semester, three for the first time and one for the third time, having received Title IV aid and earning a grade of "D" for the repeated course the two previous times.  Because an institution may pay a student only one time for retaking previously passed coursework, the repeated course would not be counted towards the student’s enrollment status and would not be eligible for Title IV aid.  If the student then ceases attendance in the three courses he is taking for the first time, the student is a withdrawal for Title IV purposes, even though the student remains enrolled in the course he is repeating, because he ceased attendance in the Title IV eligible part of the program scheduled for that period.

Likewise, if a student who received an incomplete in a course in the prior term is completing the coursework in the subsequent term to erase the incomplete from the prior term, the student is not eligible for Title IV, HEA program funds for completion of the coursework.  If the student withdraws from all the Title IV eligible coursework in which he or she is enrolled, but remains in attendance in only the coursework that needs to be completed from the previous term, the student is a withdrawal for Title IV purposes.  Of course, if the student is retaking the entire course for credit in the subsequent term, the hours in the course count toward the student’s enrollment status and the student may receive Title IV, HEA program funds for retaking a failed course, or retaking a previously passed course one time.

The principle is the same for programs offered in modules.  For example, a student is scheduled to attend one course in each of five modules during a semester.  The student receives an incomplete in course number two in the second module and, because the student may not progress to course number three until course number two is completed, the student completes the remaining portion of course number two in the third module.  While the student completes the incomplete portion of course number two in the third module, he or she is not be considered to be enrolled in the course for Title IV purposes, so attendance of just that course does not count as attendance for purposes of the Return of Title IV Funds requirements.  Therefore, in accordance with the requirements for the treatment of students in program offered in modules, the institution would need to obtain written confirmation of future attendance in a Title IV eligible course later in the semester at the time that would have been a withdrawal in accordance with §668.22(a)(2)(ii), or put the student on an approved leave of absence for the student not to be considered a withdrawal for Title IV purposes.  Absent written confirmation of future attendance or being placed on an approved leave of absence, a Return to Title IV Funds calculation would be required.  However, if the student subsequently returns to a Title IV eligible course later in the period, the student’s Return of Title IV Funds calculation would be undone in accordance with §668.22(a)(2)(iii).  [Guidance issued 5/7/2012]

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Program Integrity Q&A

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