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Program  Integrity Q&A

Questions on this topic are divided into  the following categories:
                - Gen eral Questions (R2T4)
                - Programs Offered in Modules (MOD)
                - Institutions that are Required to Take Attendance (TA)
                - Enrollment Reporting (ER)
                - Grades and Incompletes (GI)
                - Withdrawal Exemptions in Programs Offered in Modules (WI)
                - Clock Hour Programs (CHP)
                - Scheduled Days in a Payment Period for a Program Offered in Modules (SD) 
                - R2T4 Calculation Freeze Date (RCFD)
                - Institutional Charges (INST)

In addition to the following Q&As, please see the following  resources for guidance related to the Return of Title IV Funds requirements:
                - Preamble to the October 29, 2010 final regulations
                - GEN-11-14         – published 7/20/2011
                - Distance Education and Innovation       Final Regulations  – published 9/02/2020
                - Webinars – New       Distance Education and Innovation Regulations: Satisfactory Academic       Progress and Return of Title IV Aid – New Regulation Overview

**General Questions (R2T4)**

R2T4-Q1: How does the July 1,  2011, effective date apply to the changes to the Return of Title IV Funds  (R2T4) regulations?

R2T4-A1: Archived 

R2T4-Q2: What is the effective date of the R2T4 provisions in the July  1, 2021 regulations if an institution decides not to early-implement those  provisions?

R2T4-A2: For institutions that did not early-implement the R2T4  provisions of the regulations prior to July 1, 2021, the  regulations will apply to students who withdraw or otherwise cease attendance  (including by graduating) on or after July 1, 2021. [Guidance issued 08/20/2021]

**Programs Offered in  Modules (MOD)**

MOD-Q1: If some portions of a program are offered in modules,  but some are not, is the entire program considered to be offered in modules for  R2T4 purposes?

MOD-A1: Section 668.22(l)(6) of the regulations effective July  1, 2021 (unless early-implemented) provides that a program is offered in  modules for purposes of determining the applicability of the R2T4 requirements  if the program uses a standard term or nonstandard-term academic calendar, is  not a subscription-based program, and a course or courses in the program do not  span the entire length of the payment period or period of enrollment. The  determination of whether a program is offered in modules is made on a payment  period-by-payment period or period of enrollment-by-period of enrollment basis,  as appropriate, and is student specific. So, while some payment periods or  periods of enrollment in a student’s program may be considered to be offered in  modules, others may not. If all the courses in a program for a particular  payment period or period of enrollment, as applicable, span the entire length  of the period, the program is never considered to be offered in modules for  that period for any student who withdraws during the period. Conversely, if  none of the courses in a program for a particular payment period or period of  enrollment spans the entire length of the period, the program is always  considered to be offered in modules for that period for any student who  withdraws during the period. If some courses in the program for a particular  payment period or period of enrollment span the entire length of the period but  some do not, the program is considered to be offered in modules only for those  students who are scheduled to attend at least one course that does not span the  entire length of the period, and withdraw during the period.

For example, an institution offers a credit hour program in  semesters with two optional summer sessions. All the courses in the Fall and  Spring semesters span the entire length of the semester. The two summer  sessions are offered sequentially, and are both seven weeks long. The  institution chooses to combine the summer sessions into one term. Students have  the option to enroll in either session or both sessions. The Fall and Spring  semesters are never considered to be offered in modules for any student who  withdraws because all classes span the entire length of the payment period (the  term). However, for the summer sessions, where the payment period is the term  comprising both sessions, all students who withdraw are considered to be  withdrawing from a program offered in modules (with each session being a  module) because none of the courses offered spans the entire length of the  payment period. If, for the summer term, the institution also offered courses  that were 14 weeks in length (i.e., spanned the entire length of the payment  period) and a student who withdrew was scheduled to attend only these 14-week  long courses, the program would not be considered to be offered in modules for  purposes of determining the applicability of the R2T4 requirements to that  student’s withdrawal. [Guidance issued 07/20/2011; **revised 08/20/2021**]

MOD-Q2: Section 668.22(a)(2)(ii)(A)(1) provides that an institution is not required  to treat a student who ceases attendance in a module-based program as a withdrawal  if the institution obtains written confirmation from the student at the time  that would have been a withdrawal of the date that he or she will attend a  module that begins later in the same payment period or period of enrollment.  What does "at the time that would have been a withdrawal" mean? Do we  have to require the student to write the statement at the time they actually  withdraw, or, if we run reports on a weekly basis to identify these students,  can we request the student’s written confirmation of future attendance at that  time?

MOD-A2: "At the time that would have been a  withdrawal" means close to the date that the student actually ceased  attendance and before the time when the institution was required to return  Title IV funds, offer any post-withdrawal disbursement of loan funds, or take  any other action under the R2T4 requirements. Without confirmation of future  attendance, the institution must assume a student who has ceased attendance is  a withdrawal and begin the R2T4 process. An institution is expected to begin  the R2T4 process immediately upon its determination that a student has  withdrawn in order to perform required actions in a timely manner, and may not  delay the R2T4 process in case a student might return. Of course, because the  notice must confirm attendance in a module that begins later in the same  payment period or period of enrollment, the notice must always be obtained  prior to the beginning of the module in which the student is confirming  attendance. [Guidance issued 07/20/2011]

 MOD-Q3: Does an online confirmation of future attendance from  the student constitute written confirmation from the student that he or she  will attend a module that begins later in the same payment period or period of  enrollment?

 MOD-A3: Yes, provided that the confirmation is a timely positive  confirmation of future attendance. Thus, an institution must ensure that the  online confirmation requires the student to reaffirm attendance in a module  that begins later in the period if that attendance is the basis for the future  attendance. For example, consider a student who is scheduled to attend two  courses in the first of three modules in a period of enrollment and one course  in the third module. The student uses the institution’s online process for  dropping/adding courses to withdraw from both courses in the first module, but  does not withdraw from the course in the third module. The institution may not  assume that the student will be returning for the course in the third module  for purposes of demonstrating confirmation of future attendance. Rather, the  process must require the student to reaffirm his or her intent to attend the  course in the third module in order to count as confirmation of future  attendance for Title IV, HEA program purposes. Of course, if at the time of the  withdrawal, the student enrolled in a course in a later module in the same  payment period or period of enrollment (that the student was not previously  scheduled to attend), the newly added course would count as positive  confirmation of future attendance for Title IV, HEA program purposes. [Guidance  issued 7/20/2011]

 MOD-Q4: May an institution wait to perform a R2T4 calculation to  see if a student who has withdrawn and has not provided written confirmation of  future attendance will return later in the payment period or period of  enrollment?

 MOD-A4: No. An institution is required to "undo" the R2T4  calculation if a student who has withdrawn returns to the institution (1)  within the same payment period or period of enrollment for a term-based credit  hour program offered in modules; or (2) within 180 calendar days for a  clock-hour or non-term credit hour program (§668.22(a)(2)(iii)). An institution  is expected to begin the R2T4 process immediately upon its determination that a  student has withdrawn in order to perform required actions in a timely manner.  For example, an institution must always return any unearned Title IV funds it  is responsible for returning as  soon as possible, but no later than 45 days after the date of the  institution determination that the student withdrew (§668.22(j)(1)); disburse  directly to a student any amount of a post-withdrawal disbursement of grant  funds due as soon as  possible but no later than 45 days after the date of the  institution’s determination that the student withdrew (§668.22(a)(6)(ii)(B)(1)); and offer any  post-withdrawal disbursement of loan funds within 30 days of the date of the  institution’s determination that the student withdrew (§668.22(a)(6)(iii)(A)).  Thus, an institution may not delay the R2T4 process in case a student might  return. However, if a withdrawn student returns to the institution within the  same payment period or period of enrollment for a term-based program offered in  modules, or within 180 calendar days for a clock-hour or non-term credit hour  program, and before the R2T4 process is begun or complete, the institution is  not required to begin or complete the process. [Guidance  issued 07/20/2011]

 MOD-Q5: Under the regulations effective July 1, 2021 (unless  early-implemented), section 668.22 (a)(2)(i)(C) provides that for a student in  a standard or nonstandard-term program, excluding a subscription-based program,  the student is considered withdrawn if not scheduled to begin another course  within a payment period or period of enrollment for more than 45 calendar days  after the end of the module the student ceased attending, unless the student is  on approved leave of absence. Section 668.22 (a)(2)(i)(D) provides that a  student in a non-term program or a subscription-based program is considered  withdrawn if the student is unable to resume attendance within a payment period  or period of enrollment for more than 60 calendar days after ceasing  attendance, unless the student is on an approved leave of absence. If a student  is a withdrawal under §668.22 (a)(2)(i)(C) or 668.22 (a)(2)(i)(D) because the  student, who has completed a module or course in the payment period or period  of enrollment, but does not meet any R2T4 withdrawal exemption and is not  scheduled to attend another course in the payment period or period of  enrollment in the required timeframe, what is the student’s withdrawal date?

 MOD-A5: For an institution that is required to take attendance,  a student’s withdrawal date is always the last date of academic attendance as  determined by the institution from its attendance records (§668.22 (b)(1)). For  an institution that is not required to take attendance, the withdrawal date is  determined in accordance with the requirements of §668.22 (c). [Guidance issued 07/20/2011; **revised 08/20/2021**]

 MOD-Q6: For regulations effective July 1, 2021 (unless early  implemented) may an institution have a more onerous policy for a standard or  nonstandard term program that requires the student to resume attendance in a  later module within the payment period or period of enrollment in less than 45  days; for example, no more than 30 days after the end date of the module that  the student completed or ceased attending?

 MOD-A6: If an institution has a policy to administratively  withdraw a student who does not begin attendance in another course within a  period of time that is less than the 45-day period described in §668.22  (a)(2)(i)(C), the student would be considered a withdrawal for Title IV, HEA  program purposes and the institution must determine the student’s withdrawal  date in accordance with the requirements for administrative withdrawals. For an  institution that is required to take attendance, a student’s withdrawal date is  always the last date of academic attendance as determined by the institution  from its attendance records (§668.22 (b)(1)). At an institution that is not  required to take attendance, an administrative withdrawal is considered to be a  withdrawal without student notification due to circumstances beyond the  student’s control, and the withdrawal date is the date that the institution  determines is related to that circumstance (§668.22 (c)(1)(iv)). The withdrawal  date should be no later than the starting point of nonattendance that causes  the institution to administratively withdraw the student. Thus, the last  possible date of withdrawal for a student that is administratively withdrawn  due to a period of nonattendance for a specified period is the beginning of the  period of nonattendance that triggered the administrative withdrawal. [Guidance issued 07/20/2011]

 MOD-Q7: If a student who withdrew from a term-based credit hour program  offered in modules (excluding subscription-based programs) without providing  written confirmation of future attendance later returns during the payment  period or period of enrollment, thus requiring the institution to “undo” the R2T4  calculation in accordance with §668.22 (a)(2)(iii)(A), does the institution  restore Title IV, HEA program funds to the amounts the student was originally  scheduled to receive, or adjust those amounts to take into consideration  periods the student was originally scheduled to attend, but did not attend?

 MOD-A7: If a student withdraws from a term-based program offered  in modules (excluding subscription-based programs), triggering a R2T4  calculation, and the student reenters the same program during the payment  period or period of enrollment, the institution must restore the student’s  original Title IV, HEA program funds award to the original amounts, with no  adjustments required for partial attendance of a module. However, if a student  did not attend an entire module he or she was originally scheduled to attend  during the time he or she was away from the institution, the institution must  adjust the student’s original Title IV, HEA program fund amounts to take into  account that the student never began the courses in that module. [Guidance issued 07/20/2011]

 MOD-Q8: If a student ceases attendance between modules—that is,  the student completes one or more modules, but does not begin the next module  he or she is scheduled to attend—is the student considered a withdrawal for  Title IV, HEA program purposes? 

 MOD-A8: When determining whether a student enrolled in modules  is a withdrawal for Title IV, HEA program purposes, an institution should  consider:

 1. Did the student cease to  attend, or fail to begin attendance in a scheduled course that was included in  the institution’s calculation of the student’s Title IV awards for the payment  period or period of enrollment?

* If yes, go to question 2      * If no, the student is not a  withdrawal 

2. When the student ceased to attend  or failed to begin attendance in a scheduled course, was the student attending  other courses in the period?

* If yes, the student is not a  withdrawal, but Pell recalculations may apply      * If no, go to question 3

3. When the student ceased to attend  or failed to begin attendance in a scheduled course, did the student complete  all the requirements for graduation?

* If yes, the student is not a  withdrawal, but Pell recalculations may apply      * If no, go to question 4

4. When the student ceased to  attend or failed to begin attendance in a scheduled course, did the student  successfully complete:      * a module or combination of  modules that contain 49 percent or more of the number of days of the payment  period (excluding scheduled breaks of 5 consecutive days or more and all days  between modules); OR      *coursework equal to or greater  than the coursework required for the institution’s definition of a half-time  student for the payment period?

* If yes to either question,  student not a withdrawal, but Pell recalculations may apply      * If no, go to question 5

5. Did the student confirm  attendance in a later point in the payment/enrollment period (a module that  begins no later than 45 days after the date that the student withdrew for  standard or nonstandard programs; or a date that is no later than 60 days from  the date the student ceased attendance for non-term or subscription-based  programs, as applicable)?

* If yes, the student is not a  withdrawal, but Pell recalculations may apply      * If no, the student is a withdrawal

[Guidance issued  07/20/2011; **revised  08/20/2021**]

MOD-Q9: Section 668.22(f)(1)(i)  provides that the percentage of the payment period or period of enrollment  completed is determined for a credit hour program by dividing the total number  of calendar days in the payment period or period of enrollment into the number  of calendar days completed in that period as of the student’s withdrawal date.  If a student ceases attendance in the first of three modules he or she is  scheduled to attend in a payment period or period of enrollment and  subsequently drops the classes in the two remaining modules prior to the  beginning of module two, does the total number of calendar days in the payment  period or period of enrollment include all the days in all the modules, or just  the first module? What if the student drops the classes in the two remaining  modules prior to ceasing attendance in the first module?

MOD-A9:  Archived

 MOD-Q10: When performing an R2T4 calculation, are the days  between modules included in the total number of calendar days in the period?

 MOD-A10: The total number of calendar days in the payment period  or period of enrollment includes all days in the payment period or period of  enrollment, excluding days in which the student was on an approved leave of  absence, and scheduled breaks of at least five consecutive days when the  student is not scheduled to attend a module or other course offered during that  period of time. So, breaks between modules that the student is scheduled to attend  of at least five consecutive days are excluded from the total number of  calendar days in the period when calculating the percentage of the period  completed by the student. These breaks would be excluded both in the numerator  and the denominator of the R2T4 calculation (§668.22(f)(2)(ii)(B)). 

 Please note this only applies to the process for determining the  denominator for the R2T4 calculation. This is not the process for determining  whether a student successfully completed at least 49 percent of the payment period  for purposes of determining whether the student qualifies for an exemption from  the R2T4 requirements (see question WI-Q4 below). [Guidance issued 07/20/2011; **revised 08/20/2021**]

 MOD-Q11: Section 668.22(c)(1)(iii) provides that the withdrawal  date for a student who withdraws from an institution that is not required to  take attendance when the student does not provide official notification to the  institution of his or her withdrawal (i.e., unofficially withdraws), is the  midpoint of the payment period or period of enrollment. If a student  unofficially withdraws from a program offered in modules at an institution that  is not required to take attendance, how is the student’s withdrawal date (the  midpoint of the period) determined?

 MOD-A11: The midpoint of the payment period or period of  enrollment would be the 50 percent point of the total number of calendar days  in the payment period or period of enrollment. The total number of calendar  days in the payment period or period of enrollment includes all days in the  payment period or period of enrollment, excluding days in which the student was  on an approved leave of absence, and scheduled breaks of at least five  consecutive days when the student is not scheduled to attend a module or other  course offered during that period of time (§668.22(f)(2)). Consider a student  who, after completing the first module (and does not qualify for a withdrawal  exemption), withdraws on day 20 of the second module of a period comprising two  eight-week modules with a four-day break in between. Because there are no  scheduled breaks of at least five consecutive days during or between the  modules, the total number of calendar days in the period would be the total  number of days in each module (8 weeks x 7 days=56 days in each module; 56 days  x 2 modules=112 days in the modules) plus the 4 days in between the modules  (112 days in the modules + 4 days between modules) for a total of 116 calendar  days in the period.) Therefore, the midpoint and, thus, the withdrawal date  would be day 58. 

 Note that there may be situations where the withdrawal date  determined using this method occurs slightly before or after the 50 percent  point in the term. For example, the midpoint of a term that includes 117  calendar days would be the 59th day of the term because the institution, using  normal rounding rules, would round the result of the calculation (58.5) to 59.  In such cases, an institution must always treat the student as having earned  exactly 50 percent of their Title IV funds for the period even if the  calculation based on the withdrawal date at the midpoint would otherwise result  in a different percentage (for example, 59 divided by 117 equals 50.4 percent).		[Guidance issued 07/20/2011; **revised 08/20/2021**]

 MOD-Q12: The preamble to the final regulations effective July 1,  2011 states, “If the student has not begun attendance in enough courses to  establish a half-time enrollment status, the institution may not make a first  disbursement of a Direct Loan to a student (34 CFR 685.303(b)(2)(i))” (75 FR  66895 (October 29, 2010)). Does this mean that an institution must delay the  first disbursement of Direct Loan funds until the student has begun attendance  in enough hours to qualify as a half-time student?

 MOD-A12: No, an institution is not required to delay the first  disbursement of a Direct Loan until the student has begun attendance in enough  classes to qualify as a half-time student. The statement in the preamble refers  to a post-withdrawal disbursement of Title IV, HEA program funds—i.e., a  disbursement of Title IV, HEA program funds made after the student withdraws  that were earned but not received by the student while still attending the  institution—to a student who is withdrawing from a program offered in modules,  where the student has not begun attendance in all the courses in all the  modules the student was originally scheduled to attend. Title IV, HEA program  funds are disbursed to a student on the presumption that he or she will attend  the hours for which aid has been awarded. Therefore, an institution is not  required to delay the disbursement of Title IV, HEA program funds until a  student has attended enough hours to qualify for the enrollment status for  which the funds were awarded. However, if the student has withdrawn and has not  begun attendance in enough courses to establish a half-time enrollment status,  the presumption is no longer valid. Thus, the institution may not make a first  disbursement of a Direct Loan (i.e., the first disbursement of a Direct Loan in  a loan period) to a student. Section 668.164(g)(3)(iii), which permits an  institution to make a late disbursement of a Direct Loan for costs incurred to  a student who did not withdraw, but ceased to be enrolled as at least a  half-time student, does not apply because the student never really was a  half-time student. Take, for example, a credit hour program where each semester  comprises three modules of five weeks each. If a student enrolls in one  three-credit course in the first module, and one three-credit course in the  second module, the student will not begin attendance in six credit hours, the  institution’s minimum half-time enrollment status, until starting the course in  the second module. The institution is not required to, nor should it, delay the  disbursement of the student’s Direct Loan program funds until the student  begins the course in the second module. However, if the student withdraws  during the first module and the institution has not made the first disbursement  of a Direct Loan to the student prior to the withdrawal, the institution may  not make that first disbursement of the Direct Loan to the student at this  point. [Guidance issued 07/20/2011; **revised 08/20/2021**]

 MOD-Q13: The preamble to the final regulations effective July 1,  2011 states, "If the student has not begun attendance in enough courses to  establish a half-time enrollment status, the institution may not make a first  disbursement of a Direct Loan to a student (34 CFR 685.303(b)(2)(i)), or a  second disbursement of Pell Grant funds, although the funds are included as aid  that could have been disbursed in the R2T4 calculation." (75 FR 66895  (October 29, 2010).) Why is an institution prohibited from making a second  disbursement of Pell Grant funds?

 MOD-A13: The preamble to the July 1, 2011 regulations is  incorrect. An institution would not be prohibited from making a second  disbursement of Pell Grant funds if the R2T4 calculation resulted in a  post-withdrawal disbursement of Pell Grant funds. We published a correction to  the preamble language in the Federal Register on April 13, 2011 (76 FR 20534). [Guidance issued 07/20/2011; **revised 08/20/2021**]

 MOD-Example— Archived 

 MOD-Q14: If a student who is scheduled to attend all three  modules in a payment period or period of enrollment drops the classes in the  two remaining modules in the period between the first and second module (when  the student is not attending any classes), are the days in modules two and  three included in the total number of calendar days in the payment period or  period of enrollment?

 MOD-A14: Archived 

 MOD-Q15: If a student (or an institution) drops classes on the  same day that the student withdraws, is the student's enrollment status  adjusted to reflect the dropped classes for R2T4 purposes?

 MOD-A15: Archived 

 MOD-Q16: Because of the requirements for retaking coursework,  students are sometimes completing or repeating coursework for which they may  not receive Title IV, HEA program funds. If a student withdraws from all other  courses in the payment period or period of enrollment, as applicable, except for  the non-Title IV eligible course(s) they are completing or repeating, are they  a withdrawal for Title IV purposes? How does this apply to programs offered in  modules?

 MOD-A16: 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  R2T4 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 (absent withdrawal exemptions or the student completing more than 60  percent of the period before withdrawing). However, if the student subsequently  returns to a Title IV eligible course later in the period, the student’s R2T4  calculation would be undone in accordance with §668.22(a)(2)(iii). [Guidance issued  5/7/2012]

 MOD-Q17: If a student who withdrew from a non-term credit hour  program failed hours in the payment period, must the payment period be extended  by the number of days necessary for successful completion of those hours?

 MOD-A17: The total number of calendar days in the period must  reflect the actual days the student would have had to attend to successfully complete  all the hours the student was originally scheduled to complete in the period.

 Section 668.22(f)(2) provides that the total number of calendar  days in a payment period or period of enrollment includes all days within the  period that the student was scheduled to complete, except that scheduled breaks  of at least five consecutive days and days in which the student was on an  approved leave of absence are excluded from the total number of calendar days  in a payment period or period of enrollment and the number of calendar days  completed in that period. Dear Colleague Letter GEN-04-03 (November 2004)  provides that, for non-term credit hour programs, if the student has not  successfully completed any courses in the payment period, the payment period  must be extended to reflect the number of days in the failed courses that the  student did not successfully complete. Section 668.4(c) defines how payment  periods are determined for non-term credit hour programs. Completion of a  payment period occurs when a student successfully completes the hours and weeks  of instructional time in the period. Section 668.4(h) provides that a student  successfully completes credit hours if the institution considers the student to  have passed the coursework associated with those hours. If a student has not  passed all the coursework associated with the hours in the payment period (in  addition to completing the weeks of instructional time, unless the graduation  withdrawal exemption applies), the student has not completed the payment period.  So, any additional days beyond the original end date of the payment period that  it would have taken for a student to complete the credits associated with any  courses that ended prior to the student’s withdrawal that the student did not  pass must be added to the total number of calendar days in the payment period  when performing the R2T4 calculation.

 If more than one course must be added for successful completion  of the hours in the payment period and those courses could have been taken  concurrently by the student had he or she remained enrolled, then the payment  period would be extended by the days necessary to take the courses  concurrently. However, if the only way the student could have taken the courses  was consecutively, then the added days must reflect the days it would have  taken to complete the courses consecutively. If prior to a student’s  withdrawal, the student has added a course or courses to complete within the  original payment period hours previously failed, the payment period would  reflect the original end date. [Guidance issued 9/14/2012]

MOD-Q18: A student met  the conditions for a withdrawal exemption through successful completion of  coursework, but later ceased attendance in other coursework during the payment  period or period of enrollment. At the time that the student ceased attendance,  the institution had not disbursed all of the Pell Grant and Direct Loan funds  for which the student was otherwise eligible. In this situation, is the  institution permitted to disburse any remaining amounts of Pell or Direct Loan  funds?

    MOD-A18: When a student  meets the conditions for a withdrawal exemption, the student is treated as  having completed the payment period and, for purposes of the Title IV programs,  is considered enrolled through the end of the period even if the student later  stops attending future coursework or modules in that period. In that situation,  if the student had not received all of their Pell Grant or Direct Loan  disbursements for the payment period, it is possible for the student to receive  additional disbursements during the payment period depending on specific Title  IV program requirements and the Department’s cash management requirements.

    For Pell Grant purposes,  the institution must determine whether the student is subject to a mandatory  Pell recalculation because the student did not begin all classes that comprised  the student’s Pell Grant enrollment status for the period. Additionally, the  institution must disburse any remaining Pell Grant funds for which the student  is eligible before the end of the payment period. If the institution fails to  disburse all of the Pell Grant funds for which the student is eligible until  after the payment period is over, a subsequent disbursement of Pell Grant funds  for the period is treated as a retroactive or late disbursement that is subject  to all requirements for such disbursements, including the requirement under 34  CFR 690.76(b) that the student’s Pell Grant enrollment status must be  determined according to work already completed.

    For Direct Loan  purposes, when a student ceases attendance during a payment period after  meeting the conditions for a withdrawal exemption, the institution must  disburse Direct Loan funds for which a student is eligible during the payment  period only if the student is enrolled at least half time at the time of  disbursement. If the student ceased attendance prior to attending coursework  that comprised at least half-time enrollment, it is impossible for that student  to enroll half-time during the period unless the student resumes attendance  later in the period. Therefore, in this situation the institution cannot make  the Direct Loan disbursement unless it confirms that the student commenced  attendance in coursework that comprises at least half-time attendance during  the payment period. If the institution fails to make the disbursement of Direct  Loan funds until after the payment period is over, the disbursement is treated  as a retroactive or late disbursement that is subject to all requirements for  such disbursements.

    As an example, consider  a student who enrolls in two eight-week modules within a payment period. The  student enrolls in one three-credit class in each module for a total of six  hours, which meets the institution’s definition of half-time enrollment. The  student is awarded Pell Grant and Direct Loans, but due to administrative  delays the institution is unable to make the Title IV disbursements while the  student is still in attendance.

    As of the institution’s  Pell recalculation date the student is enrolled half time. The student  successfully completes the first module and meets the conditions for a  withdrawal exemption. The student then begins the second module, but ceases  attendance prior to receiving any Title IV disbursements for the period. The  student is considered a completer and, for Title IV purposes, remains enrolled  throughout the entire payment period.

    The student qualifies  for a Pell Grant disbursement at half-time enrollment status because the  student was enrolled half-time on the Pell recalculation date and the student  began attendance in coursework sufficient to comprise half-time enrollment. For  Direct Loan purposes, the student was enrolled half-time and had begun  attendance in coursework that comprised half-time enrollment at the time the  student ceased attendance. Therefore, the institution must disburse the Direct  Loan funds for which the student is eligible during the payment period.

    This scenario would  change significantly if, after completing the first module, the student never  began attendance in the second module. In that case, since the student never  began attendance in coursework sufficient for half-time enrollment, the student  would be subject to a mandatory Pell Grant recalculation and would only qualify  for a less-than-half-time Pell Grant disbursement. In this circumstance, the  student would also be ineligible to receive Direct Loan funds for the period  because the student never commenced attendance in coursework comprising  half-time enrollment. [Guidance issued 08/20/2021 - archived, **revised  11/24/21**]

 MOD-Q19: Our institution has three summer periods in which  students can enroll in coursework and those sessions are combined into a single  summer term for the purposes of awarding Title IV funds. Is our summer term  considered to be offered in modules?

 MOD-A19: Yes. If an institution combines multiple summer  sessions into a single term for Title IV purposes, and none of those sessions  span the entire term, each of the summer sessions is considered a module and a student  enrolling in any one of those session is treated as being enrolled in a program  offered in modules for that term. [Guidance issued 08/20/2021]

**Institutions that are Required to Take Attendance  (TA)**

TA-Q1: Guidance disseminated by the Department in Dear Colleague  letter GEN 04-03 (February 2004) and revised in Dear Colleague letter GEN 04-12  (November 2004) provides that, for an institution that is required to take  attendance, except in unusual instances, the date of the institution’s  determination that the student withdrew should be no later than 14 days after  the student’s last date of attendance as determined by the institution from its  attendance records. Does this 14-day rule for determining a withdrawal apply to  all institutions that fall under the definition of an institution that is  required to take attendance (i.e., those required to take attendance by an  outside entity, those that have an institutional requirement to take  attendance, and those that can only meet an externally or internally imposed  requirement by taking attendance or a comparable process)? How does the 14-day  rule apply when a student is not treated as a withdrawal from a program offered  in modules because he or she has confirmed attendance in a module that begins  later in the payment period or period of enrollment?

TA-A1: The 14-day rule applies to all institutions that are  required to take attendance. Institutions that are required to take attendance  are expected to have a procedure in place for routinely monitoring attendance  records to determine in a timely manner when a student withdraws. The 14-day  rule provides that, for an institution that is required to take attendance,  except in unusual instances, the date of the institution’s determination that  the student withdrew should be no later than 14 days after the student’s last  date of attendance as determined by the institution from its attendance  records, except that we are modifying the 14-day rule from the guidance  provided in Dear Colleague letter GEN 04-03 (February 2004) and revised in Dear  Colleague letter GEN 04-12 (November 2004) to address the situation where a  student is not treated as a withdrawal from a program offered in modules  because he or she has confirmed attendance in a module that begins later in the  payment period or period of enrollment. When in accordance with §668.22(a)(2)(ii)(A)  or (B) a student is not treated as a withdrawal from a program offered in  modules at an institution that is required to take attendance because the  student has confirmed attendance in a module that begins later in the payment  period or period of enrollment, no action is required by the institution unless  the student does not return as scheduled. If the student does not return as  scheduled, the student is treated as a withdrawal (see  §668.22(a)(2)(ii)(C)(1)), and the date of the institution’s determination that  the student withdrew should be no later than 14 days after the date that the  student was scheduled to resume attendance. For example, a student enrolls at  an institution that is required to take attendance for one course in each of  three modules. The student completes the first module, but ceases attending the  second module on October 4, prior to its completion. The student provides  written confirmation that he will attend the third module, scheduled to begin  October 24, but does not return. The institution must complete a R2T4  calculation using October 4—the student’s last date of academic attendance as  determined by the institution from its attendance records—as the withdrawal  date, and October 24 as the date of the institution’s determination that the  student withdrew. 

 In accordance with the previous guidance, if a student provides  notification to the institution of his or her withdrawal prior to the date that  the institution normally would determine that the student withdrew, the date of  determination is the date of the student's notification. The institution is NOT  required to administratively withdraw a student who has been absent for 14  days. However, after 14 days, it is expected to have determined whether the  student intends to return to classes or to withdraw. If the student is  eventually determined to be a withdrawal, the end of the 14-day period begins  the timeframe for completing a R2T4 calculation. If an institution has a policy  that states the maximum number of excused absences that can occur after which a  student will be administratively withdrawn, it may delay contacting the student  until that date. However if the student eventually is determined to be  withdrawn, the date of determination of the student’s withdrawal remains 14 days  from the student’s last day of attendance. If the number of days in the  institution’s policy is less than 14 days, then the date of the institution’s  determination that the student withdrew is the date the institution’s policy  indicates that the student will be administratively withdrawn. An institution  must return the amount of Title IV funds for which it is responsible as soon as  possible, but no later than 45 days after it determines or should have  determined that the student withdrew. In addition, if a student is due a  post-withdrawal disbursement, then the date of the institution’s determination  must allow for the institution to meet the 30-day post-withdrawal disbursement  notification requirement. This requirement does not affect a student’s withdrawal  date. At an institution that is required to take attendance, a student’s  withdrawal date is always the last date of attendance as determined by the  institution from its attendance records. [Guidance issued 7/20/2011]

 For additional information on the date of the institution’s  determination that the student withdrew, see Volume 5—Overawards, Overpayments,  and Withdrawal Calculations, Chapter 2—Withdrawals and the Return of Title IV  Funds, of the Federal Student Aid Handbook.

TA-Q2: If an institution monitors whether its online students  log into classes, is this an institution that is required to take attendance?

TA-A2: No. The monitoring of whether online students log into  classes does not by itself result in an institution being an institution that  is required to take attendance for Title IV, HEA program purposes because  monitoring logins alone is not monitoring academic engagement (as defined under  34 CFR 600.2). However, an institution that collects and maintains information  about students’ online activities for the purpose of tracking academic  engagement is considered to be an institution that is required to take  attendance if that tracking:

 1) Involves monitoring student attendance in a synchronous  class, lecture, recitation, or field or laboratory activity, physically or  online, where there is an opportunity for interaction between the instructor  and students; or

 2) Is used to administratively withdraw students or to enforce an  institutional attendance policy.

[Guidance issued 7/20/2011; **revised 08/20/2021**]

TA-Q3: If a student officially withdraws after the end of a  limited period of required attendance taking, does the institution have to  demonstrate that the student was in attendance after the attendance-taking  period in order to determine the student’s withdrawal date under the  requirements for an institution that is not required to take attendance?

TA-A3: Yes. Unless an institution that is required to take  attendance for a limited period can demonstrate that a student who was not in  attendance at the end of the limited period attended after that period, the  student’s withdrawal date is determined according to the requirements for an  institution that is required to take attendance (75 FR 66901 (October 29, 2010)).  That is, the student’s withdrawal date is the last date of academic attendance  during the period of attendance taking, as determined by the institution from  its attendance records. Take, for example, a student who is not in attendance  in his or her classes on the last day of a two-week period of required  attendance taking. The student begins the institution’s withdrawal process two  weeks after the end of the two-week period of required attendance taking. The  institution must demonstrate that the student was in attendance after the  two-week attendance-taking period in order to use the date the student begins  the institution’s official withdrawal process as the withdrawal date. If it  cannot, the student’s withdrawal date is the last date of academic attendance  during the period of attendance taking, as determined by the institution from  its attendance records. [Guidance issued 7/20/2011]

TA-Q4: If an institution requires its faculty to provide a last  date of attendance for students who receive all “F” grades to determine whether  a student with failing grades has unofficially withdrawn, is this an  institution that is required to take attendance?

TA-A4: No. A requirement that faculty provide a last date of  attendance for students who receive all “F” grades to determine whether a  student with failing grades has unofficially withdrawn does not make an  institution one that is required to take attendance for Title IV, HEA program  purposes. Only if the institution requires its faculty to collect or record  information about whether a student was in attendance is it considered to be  one that is required to take attendance. For additional information on  determining whether a student who failed to receive a passing grade is a withdrawal,  see Volume 5—Overawards, Overpayments, and Withdrawal Calculations, Chapter 1—Withdrawals  and the Return of Title IV Funds, of the Federal Student Aid Handbook.  [Guidance issued 7/20/2011; **revised 08/20/2021**]

TA-Q5: If an institution requires its faculty to take attendance  for some courses in a program, but not others (for example, all core courses,  but not elective courses), is this an institution that is required to take  attendance?

TA-A5: An institution is only required to take attendance if  attendance taking is required in all classes in the program for a period of  time. If, for example, an institution requires that attendance be taken in all  core courses, but not elective courses, and the core and elective courses are  always taken together throughout a payment period, then the institution would  not be classified as being required to take attendance for that program because  attendance taking is not required for all courses for any period of time.  However, if the core courses in the program are taken together in isolation—for  example, over the first five weeks of a payment period—then this would be a  program for which the institution is required to take attendance for those  first five weeks because, for that period of time, attendance is required in all  courses. [Guidance issued 7/20/2011]

TA-Q6: Please confirm that an institution is not an institution  that is required to take attendance if it has a census that reviews which  students academically attended during a defined preceding period--e.g.,  determines who attended during the first two weeks of a course--rather than  being limited to students’ academic attendance on just one date.

TA-A6: Section 668.22 (b)(3)(iv) provides that an institution is  not an institution that is required to take attendance for Title IV, HEA  program purposes if the institution takes attendance on only one specified day  to meet a census reporting requirement. So, if the institution is taking  attendance on just the 14th day, it is not an institution that is required to  take attendance for Title IV, HEA program purposes. Also, if the institution is  taking attendance to determine whether each student attended at least once  during the period, but is not continuing to monitor attendance for a student  subsequent to the one day of attendance, it is not an institution that is  required to take attendance for Title IV, HEA program purposes. If, however,  the institution is taking attendance throughout the two weeks to determine when  students are and are not present, then in accordance with §668.22(b)(3)(iii),  the institution is taking attendance for a limited period and the institution  is one that is required to take attendance for Title IV, HEA program purposes  for that limited period. [Guidance issued 7/20/2011]

TA-Q7: For a program that is offered in modules, may the  institution require that attendance be taken on only one specified day for each  module (i.e., have one census date per module) without the institution being  considered an institution that is required to take attendance for Title IV, HEA  program purposes.

TA-A7: Yes. [Guidance issued 7/20/2011]

TA-Q8: If faculty at an institution are required to take  attendance and some faculty do not comply with the requirement, how should the  institution determine a withdrawal date for a student who withdraws?

TA-A8: If attendance taking is required, either by an outside  entity, the institution itself, or the institution or the outside entity has a  requirement that can only be met by taking attendance or a comparable process,  the institution is one that is required to take attendance for Title IV, HEA  program purposes and the student’s withdrawal date is always the last date of  academic attendance as determined by the institution from its attendance  records. The institution is responsible for ensuring that it is in compliance  with the requirement to take attendance. If some faculty does not comply with  the required attendance taking, a student’s withdrawal date will be the last  date of academic attendance from the attendance records taken by the faculty  that did take attendance. If no records of a student’s academic attendance  exist, the student is considered not to have begun attendance for Title IV, HEA  program purposes and, therefore, never established eligibility for the Title IV,  HEA program funds. The Title IV, HEA program funds must be handled by the  institution in accordance with the requirements for the treatment of Title IV  grant and loan funds if the recipient does not begin attendance at the  institution in §668.21, rather than the R2T4 requirements in §668.22. [Guidance  issued 7/20/2011]

TA-Q9: For institutions required to take attendance, if a  student in a non-term program does not provide written confirmation to resume attending  within 60 calendar days after the student ceased attendance, does the date of  the institution’s determination need to be no later than 14 days after the  student’s last date of attendance?

TA-A9: Yes, except in unusual circumstances, the date of the  institution’s determination that the student withdrew should be no later than  14 days after the student’s last date of attendance as determined by the  institution from its attendance records, including in cases where a student  fails to provide written confirmation of his/her intent to return to a module  later in the same payment period or period of enrollment. [Guidance issued 08/20/2021]

TA-Q10: One of our students completed an online orientation  prior to the start of a term, but we have no record of academic engagement  after the term started. Can we use documentation of the student’s participation  in the orientation as a record of attendance?

TA-A10: Only active participation by a student in an  instructional activity related to the student's course of study that meets the  definition of “academic engagement” in 34 CFR 600.2 and takes place during a payment  period or period of enrollment qualifies as attendance in an academically  related activity. If a period of orientation takes place prior to the start of  a course, it would not qualify as attendance in an academically related  activity. 

Additionally, an orientation may or may not be considered academic  engagement depending on the types of activities that are involved in the  orientation. Neither the definition of academic engagement nor the Department’s  guidance provide an exhaustive list of the types of activities that could be  considered academic engagement. Institutions should make clear what will and  will not be considered academic engagement in their policies and procedures and  apply those policies and procedures consistently to all students. [Guidance  issued 08/20/2021]

**Enrollment Reporting (ER)**

ER-Q1: If a student withdraws during a payment period but is not  subject to the R2T4 requirements due to a withdrawal exemption, is the student  reported to the National Student Loan Data System (NSLDS) as a withdrawal? If so,  what should the institution use as the effective date of the withdrawal?

ER-A1: There are occasions when a student is considered  withdrawn for enrollment reporting purposes but no R2T4 calculation has to be  performed (such as when a student completes a term but does not return for a subsequent  term). If the student is not treated as a withdrawal and there is no R2T4  calculation, then the institution does not have to use the R2T4 process to  determine the effective date of the withdrawal for NSLDS enrollment reporting  purposes.

When a student completes a term and does not return for the next  term, leaving the course of study uncompleted, the effective date for the “W”  (withdrawn) status is the final day of the term in which the student was last  enrolled. This guidance remains in effect under the Distance Education and  Innovation regulations effective July 1, 2021, which treat students as having  completed a term when they meet the conditions for an exemption from treatment  as a withdrawal.

Therefore, when a student is treated as having completed a term  (e.g., because the student successfully completes a module or modules  comprising at least 49 percent of the term), but has not graduated, the institution  must report the student as withdrawn as of the *final day of the payment  period in which the student was last enrolled*. Conversely, if the student  is treated as a withdrawal and the R2T4 requirements apply, the institution  must report the student as withdrawn with an effective date as determined under  34 CFR 668.22. 

If a student meets the conditions for a withdrawal exemption for  graduating or completing all requirements for graduation, the institution may  continue to follow the current graduation requirements outlined in the NSLDS Enrollment  Reporting Guide, which indicate that “the effective date for a  completion/graduation status (“G”) is the date that the institution assigns to  the completion/graduation.”

Therefore, when a student graduates during a term upon  completion of a module with an end date that occurs prior to the end date of  the term, the institution should use the effective date that it assigns for  graduation. This effective date could be the end of the module, the date that  the credential was conferred, the term end date, or another date consistent  with the institution’s policies for assigning a graduation date. [Guidance  issued 08/20/2021]

ER-Q2:  Per 34 CFR § 690.11, a student is not entitled to receive Pell Grant payments  concurrently from more than one institution or from the Secretary and an  institution. If a Pell eligible student withdraws from one institution but  meets one of the R2T4 withdrawal exemptions and subsequently enrolls at a  different institution during the same payment period, per ER-A1 the student  would not be reported to NSLDS as withdrawn until the final day of the payment  period in which the student was last enrolled. Since the student would not be  actually withdrawn until the end of the payment period, could the student  receive Pell for attending any remaining portion of the concurrent payment  period at the second institution?  

ER-A2:  Yes, the student could receive Pell Grant funds they are eligible for during  the concurrent payment period at the second institution. For Pell purposes the  phrase “concurrently from more than one institution” means that the student must  actually be “attending” both schools at the same time for the concurrent Pell  Grant prohibition to apply. Because the student in this example was no longer  attending the original institution, the new institution can award Pell Grant  funds for any remaining portion of the overlapping payment period. For more  information on calculating remaining eligibility please see Volume 3, Chapter 3  of the 2022-2023 FSA Handbook under “Calculating  remaining eligibility”. The new institution should maintain documentation in  the student’s file supporting a Pell Grant disbursement for ceasing attendance  at the prior school in the event of an audit or program review. Please note  that your school cannot rely on the data in NSLDS for documentation purposes,  therefore, you will have to independently document when the student ceased  attendance. This is because NSLDS does not document the last date of actual  attendance in these cases, but instead, records the student as being withdrawn  as of the final day of the payment period. Independent documentation can  include documentation from the first school noting when the student ceased  attendance. 

The Common Origination and Disbursement (COD) system may provide a  concurrent enrollment warning edit (69) for these students, but as long as the  student is no longer attending the prior school, and the new school can  document that there is no concurrent attendance, they may disburse Pell Grant  funds during the overlapping payment period as noted above. [Guidance issued 05/4/2023]

**Grades and Incompletes (GI)**

GI-Q1: Our institution maintains a grading policy that  distinguishes between students who completed a course, but who failed to  achieve the course objectives (an “earned “F” grade”) and students who failed  to complete the course (a “W” grade). The Department provides that a student is  not considered withdrawn if the student receives an “earned F” (as explained in Dear Colleague Letter  GEN-04-03) at the  end of a module and is not scheduled to attend any subsequent modules during the  term. Is an “earned F” in this context considered a passing grade that denotes  successful completion of the module for withdrawal exemption purposes?

GI-A1: No. Successful completion means earning a passing grade under  an institution’s overall academic grading policy. Courses in which a student  received grades that are not passing, including earned or unearned “F” grades, an  incomplete grade (“I”) or a withdrawal (“W”) grade, are not considered to have  been successfully completed and cannot be used to determine if the student  qualifies for a withdrawal exemption.

To qualify for a withdrawal exemption for successfully  completing a module that comprises at least 49 percent of the days in a payment  period (excluding scheduled breaks of five or more consecutive days and all  days between modules), a student would need to earn a passing grade in at least  one course offered in that module. Similarly, to be considered to have completed  a combination of modules that comprises at least 49 percent of the days in the  payment period (excluding scheduled breaks of five or more consecutive days and  all days between modules), the student must have earned a passing grade in at  least one course in each of the modules that were used to calculate whether the  student met the conditions for the exemption. [Guidance issued 08/20/2021]

GI-Q2: Our institution’s general grading policy states that a  “D” grade is considered passing. However, in one of our graduate programs, a  course does not count toward completion of the student’s program unless the  student earns a grade of “C” or better. If a student in this program earns a “D”  grade, which is a passing grade per the institution’s general grading policy,  but the specific graduate program requires a “C” grade for successful completion  of a course, is the “D” grade considered successful completion for purposes of  the withdrawal exemptions?

GI-A2: Yes. Successful completion for purposes of the withdrawal  exemptions should be based on an institution’s general grading policy and not  the individual program grading policies. Therefore, if an institution’s general  institutional grading policy has established that a “D” grade is considered a passing  grade, then receipt of a “D” grade for a course would be considered successful  completion of that course for the purposes of determining whether a withdrawal  exemption applies. In this specific example, the “D” grade would be considered  successful completion for the purpose of determining if the student qualifies  for a withdrawal exemption. [Guidance issued 08/20/2021]

GI-Q3: We have a student who received “earned F” grades in each course  in each module for which the student enrolled. We know that the student does  not qualify for one of the withdrawal exemptions because an “F” grade is not  considered “successful completion” of a course. However, if we determine they  completed the full semester, would we be required to treat the student as  withdrawn and complete an R2T4 calculation? 

GI-A3: A student who receives at least one “earned F” grade at  the end of the last module that the student was scheduled to attend during the  period is not considered withdrawn. As provided in Dear Colleague Letter  GEN-04-03, an institution with a grading policy that distinguishes  between an “earned F” and an “unearned F,” a student is not considered  withdrawn if the student ceases attendance at the end of a module or class for  which the student receives an “earned F” and is not scheduled to attend any  other course or module during the period. [Guidance issued 08/20/2021]

GI-Q4: At the end of a term, a student has ceased attendance and  does not meet any of the conditions for a withdrawal exemption, but received  incomplete (“I”) grades for all the courses in which the student was enrolled  during the term. Can we treat this student as having completed the payment  period, or do we need to perform an R2T4 calculation?

GI-A4: In term-based  programs, students who are unable to complete the requirements of an individual  course are often assigned the grade of incomplete (“I”). Students are usually  expected to complete the required work within a reasonable time to receive  credit and a passing grade. However, an incomplete (“I”) grade does not  constitute completion of a course, and a student who ceases attendance does not  meet any of the conditions for a withdrawal exemption, and has not received an  “earned F” or similar grade, must be considered withdrawn (unless the student is on an  approved leave of absence, see below for more explanation).

In general, an institution  must perform an R2T4 calculation for a student within the required timeframe  unless it has evidence that the student completed the payment period or period  of enrollment. An institution can document that a student has completed a  payment period or period of enrollment if the student has received a passing  grade in the last course or courses that the student was scheduled to attend  for that period. However, if a student does not have passing grades and an  institution has no other  evidence that the student completed the period, the student must be treated as  a withdrawal (unless the student is on an approved leave of absence). Thus, if the student received only incomplete (“I”) grades and  is permitted to continue working on those courses after the end of the period,  the institution cannot presume that the student will complete the courses, and  must therefore perform the R2T4 calculation by the applicable deadline unless  the student receives a passing grade or a grade denoting completion of the course, but not the  course objectives (e.g., an “earned F”) in one of those courses prior to the  R2T4 deadline. 

Note:  In a very limited number of circumstances, a student who is awarded the grade  of incomplete (“I”) in all classes can be treated as a student on an approved  LOA, but only if the institution grants the LOA in accordance with the criteria  in 34 CFR 668.22(d). A term-based, credit-hour institution that wishes to  explore the possibility of granting an LOA that meets the criteria specified in  34 CFR 668.22(d) should call its School Participation Division for guidance.  [Guidance  issued 08/20/2021]

**Withdrawal Exemptions in Programs Offered in Modules (WI)**

WI-Q1: Do the withdrawal exemption regulations apply to both undergraduate and graduate students and programs?

WI-A1: Yes. The exemptions apply to all students who withdraw,    regardless of program level or graduate or undergraduate status. [Guidance    issued 08/20/2021]

WI-Q2: A term is broken into four consecutive five-week    modules, each of which constitutes 25 percent of the payment period. If a    student successfully completes only the first and last modules, would the    student be exempt from the R2T4 calculation even though the modules that the    student completed did not occur consecutively?

WI-A2: In a program offered in modules, a student is not    considered to have withdrawn if the student successfully completes a    combination of modules that, when combined, include 49 percent or more of the    number of days in the payment period, excluding scheduled breaks of five or more    consecutive days and all days between modules. Which modules a student    successfully completes, and in what order the modules are completed, does not    impact an institution’s determination of whether the student qualifies for a    withdrawal exemption. [Guidance issued 08/20/2021]

WI-Q3: How does an institution establish the denominator for    the calculation to determine whether a student has successfully completed at    least 49 percent of a payment period or period of enrollment? Does the    institution use the same method for determining the denominator as the R2T4  calculation itself?

WI-A3: The method for determining the denominator for the    withdrawal exemption differs from the method for determining the denominator    for the R2T4 calculation itself.

To determine the denominator of the calculation for whether a    student has successfully completed at least 49 percent of a payment period or    period of enrollment, an institution performs three steps. The institution—
                -  Adds all the days between the start and end    date of the regular term (or all the terms in the period of enrollment);
                - Subtracts any scheduled breaks of five    consecutive days or more that apply to all students who enroll in the term;    and
                - Subtracts all days between modules.

The number of days in the term for purposes of the withdrawal    exemption will be the same for all students who enrolled in that term. It    does not vary with an individual’s enrollment. Only the numerator of the    withdrawal exemption calculation – the number of days in modules that the    student successfully completed – may differ for each student.

For example, consider a term that is comprised of two modules,    each of which is 48 days in length. There are no scheduled breaks of more    than five consecutive days during the semester but there is a four-day break    between the two modules. The institution begins by adding all the days    between the start and end date of the regular term (100 days) and then    subtracting the number of days between the modules in the term (four days).    The total number of days in the denominator of the withdrawal exemption    calculation for this term is therefore 96 days. 

A student enrolls during this term in one three-credit 100-day    course and one three-credit, 48-day course in the first module. There are no    scheduled breaks of five or more consecutive days during the semester but there    is a four-day break between modules. The student successfully completes the    first module and subsequently completely withdraws from the 100-day course.    The student qualifies for the withdrawal exemption because the student has    successfully completed a module that includes days comprising 50 percent of    the days in the term (48/96 = 50 percent).

This process is different from the process to determine the  denominator in the R2T4 calculation itself. The denominator of the R2T4    calculation includes days between modules if there are fewer than five    consecutive days between modules. The denominator of the R2T4 calculation    also varies by student, and includes only the days in modules that the    student attended or that were included in the institution’s determination of    that student’s Title IV eligibility for the term. [Guidance issued 08/20/2021]

 WI-Q4: When a student enrolls in an intersession that is    connected to another term (e.g., the fall or spring term), the intersession    is treated as a module that the student is scheduled to attend and may    therefore be included in the denominator of the student’s R2T4 calculation for    a withdrawn student if the student attends the intersession or if the    intersession is included in the institution’s determination of the student’s    Title IV eligibility. Are intersessions included in the denominator for the    withdrawal exemption calculation in the same manner? 

WI-A4: No. As explained in WI-A3, the denominator of the    withdrawal exemption calculation is the same for all students who enroll in a    given term. By definition, an intersession is attached to a term and is not    part of the regular term. Therefore, the days in an intersession are always    excluded from the denominator of the withdrawal exemption calculation.    Similarly, any other days that occur outside the regular term dates (e.g., coursework    that begins prior to the regular term dates, coursework taken during a    consortium agreement, or coursework taken as part of a study-abroad program)    are never included in the denominator of the withdrawal exemption    calculation.

 For example, consider an intersession that is 40 days in    length and a regular Spring term to which it is attached that includes 80    days with no scheduled breaks. A student is scheduled to attend one full-term    course during the regular Spring term and one course during the intersession.    The student successfully completes the intersession course, but does not    attend the full-term course that the student was scheduled to attend. This    student is considered to be enrolled in a program offered in modules because    the intersession and full-term courses are both considered modules in the    student’s overall enrollment.

The denominator of the withdrawal exemption calculation    includes the 80 days in the regular term and ignores the days in the    intersession. Therefore, because the student successfully completed the intersession    course, which included 40 days (50 percent of the number of days in the    regular term), the student is treated as having completed a module comprising    at least 49 percent of the days in the regular term. This student qualifies    for a withdrawal exemption and no R2T4 calculation is required. [Guidance issued    08/20/2021]

WI-Q5: A student withdraws from a degree program in the middle    of a payment period, but graduates from a shorter certificate program (unaffiliated    with the program in which the student is enrolled as a regular student) at    that time based on coursework that was completed at the time the student withdrew.    The student did not graduate from the degree program, which was the program    in which the student was enrolled as a regular student and was the basis of    the student’s Title IV eligibility. Would the withdrawal exemption for    graduation or completion of requirements for graduation apply to this student? 

WI-A5: No. The regulations for the graduation withdrawal   exemption were intended to apply only to graduation from the program in which    the student was enrolled as a regular student and for which the student was    receiving Title IV aid for the payment period in question. The exemption does    not apply when a student graduates or receives a credential for another    program. [Guidance issued 08/20/2021]

WI-Q6: An institution only offers classes that span the length    of a payment period and a single module that begins at the start of the period    and ends in the middle of the period. Is the institution permitted to exclude    all days outside the module from the denominator of the withdrawal exemption    calculation as days that are “between modules”?

WI-A6: No. Because the institution only offers one module    during the payment period, there are no breaks “in between” modules to    exclude. The denominator of the withdrawal exemption calculation would    include all days in the normal term excluding any scheduled breaks of at    least five consecutive days. [Guidance issued 08/20/2021]

WI-Q7: We have modules of various lengths and some overlap. We    only have breaks between certain modules, but some breaks are not common to    all modules. When counting days in the modules to determine if the student    meets the conditions for a withdrawal exemption for successful completion of    a module or modules that comprise at least 49 percent of the payment period,    do we include all breaks or only breaks that are common to all modules during    the payment period?

WI-A7: For purposes of performing the calculation to determine    whether the student meets the conditions for a withdrawal exemption for    successful completion of at least 49 percent of the payment period, a day is    included in the numerator if that day was included in at least one module or    full-term course that the student successfully completed and is not part of a    break of at least five consecutive days during which no coursework was taking    place. The process for determining the number of days in the denominator of    this calculation is described in WI-A3. For either the numerator or    denominator, if a day is included in multiple overlapping modules, the day is    only counted once.

For example, if the payment period includes four modules and    there is a three-day break between each module, then the institution would    subtract nine total break days between modules from the total number of days    in the payment period. However, if the four modules overlapped one another    and there were not any breaks between modules, the institution would not    subtract any break days between modules from the denominator of the withdrawal    exemption calculation. [Guidance issued 08/20/2021]

WI-Q8: An institution offers both modules and courses that    span the entire payment period. The full-term courses have a scheduled break    of at least five consecutive days, but there is no scheduled break in the    modules as there is in the full-term courses. Should we exclude the scheduled    break in the full-term course from the denominator of the withdrawal    exemption calculation?

WI-A8: No. If a scheduled break applies to some courses in the    term, but not others, it is not excluded from the denominator of the    withdrawal exemption calculation. However, when determining the numerator of    the withdrawal exemption calculation, the institution must exclude scheduled    breaks of at least five consecutive days in each module that the student    successfully completed regardless of whether those scheduled breaks apply to    other courses in the term.

Note that the process for establishing the denominator of the    withdrawal exemption calculation differs from the treatment of scheduled    breaks for purposes of the R2T4 calculation itself. Whether an institution    excludes a scheduled break from an individual’s R2T4 calculation depends on    whether there was a scheduled break of at least five consecutive days for    that particular individual. [Guidance issued 08/20/2021]

**Clock Hour Programs (CHP)**

CHP-Q1: Our State permits students to graduate prior to    completing all of the clock hours normally established in a program if the    students can demonstrate that they have mastered all the skills in the    program. One of our students has graduated from a 900-hour clock hour program    before successfully completing all of the clock hours in the program that is    established in our institution’s Eligibility and Certification Approval    Report (ECAR). The student graduated having successfully completed only 750    clock hours. Given to the changes to the regulations effective July 1, 2021,    is this student exempt from the R2T4 requirements?

CHP-A1: Yes. Although the student did not successfully    complete all the clock hours in the program, they are not treated as a    withdrawal and the institution is not required to perform an R2T4 calculation    because the student graduated from the program.

However, allowing a student to graduate before successfully    completing the hours in the program could still require the institution to    return Title IV funds for the student. A student’s eligibility for Title IV    aid in a clock-hour program is based, in part, on the overall number of clock    hours in the student’s program of study. When an institution allows a student    to graduate from a clock hour program without completing all of the    established hours in the program, the institution has effectively shortened the    program’s length – resulting in reduced Title IV eligibility – for the    student. Therefore, if a student graduates from a clock hour program without    successfully completing all of the established clock hours in the program,    the institution must recalculate the student’s eligibility for all Title IV    aid in the program and must perform a new proration of the student’s Pell    Grants and Direct Loans as if the student had been enrolled in a program with    fewer clock hours. 

Then, if the institution had disbursed Title IV aid in an    amount greater than the amount that it recalculates, the institution must    return the difference between the recalculated amount of Title IV for which    the student was eligible based on enrollment in the shorter program and the    amount that was disbursed. The institution, not the student, is ultimately    responsible for returning the Title IV aid in these situations.

For example, if the student in this situation had a zero EFC,    the institution would have originally disbursed a full Pell Grant ($6,495 in    the 2021-2022 award year) to the student based on the student’s enrollment in    a 900-clock hour program. Assuming that the student qualified for Direct Loan    funds, the institution would also have disbursed $3,500 in Subsidized Direct    Loan funds to the student. However, when the institution allows the student    to graduate with only 750 hours, it recalculates the student’s eligibility    for both Pell Grant and Direct Loan funds as if the student had been enrolled    in a 750-hour program. To do this, the institution prorates the student’s    Pell Grant disbursements as if each disbursement were associated with a    payment period of 375 hours, resulting in two disbursements of $2,706 (375/900    * 6495). Because the institution had originally disbursed $3,247 and $3,248    in Pell Grant funds for the first and second payment periods, respectively,    the institution reduces the first disbursement by $541 and the second    disbursement by $542. The institution then returns the total difference in    Pell Grant eligibility, $1,083, to the Department. The institution also    prorates the student’s Subsidized Direct Loan award based on a program length    of 750 hours, resulting in a prorated Subsidized Direct Loan award of $2,917.    Because the institution had originally disbursed $1,750 (gross) in Direct    Loan funds for each payment period, the institution reduces the first    disbursement by $291 and the second disbursement by $292. The institution    then returns the total difference of $583 in Direct Loan funds to the    Department. 

Note that though proration of Pell Grant or Direct Loan awards    normally involves consideration of the number of weeks of instruction in the    program, when prorating a student’s awards in this situation the institution    does not consider the number of weeks of instructional time completed    by the student. This is because, as explained in CHP-A2, the Department    expects that students will progress individually through clock hour programs    and not all students will successfully complete all of the hours in a program    at the same time.

Please note that this situation is a limited exception to the    Department’s normal guidance that an institution is not required to return    Direct Loan funds for a student if the student’s eligibility is reduced after    the student has received all disbursements of the loan. The Department treats    a situation when a student graduates before successfully completing the hours    in a clock hour program as a situation where the student had graduated from a    shorter program, and therefore was never eligible for the additional funds,    including when the original disbursements were made. The Department’s normal    guidance regarding recalculation of Direct Loan eligibility presumes that the    student was eligible when the institution originally made the Direct Loan    disbursements. [Guidance issued 08/20/2021]

CHP-Q2: If a student enrolled in a clock hour program successfully    completes all of the clock hours in the final payment period, but does so    before completing all of the instructional weeks scheduled in the payment    period, would that also require re-proration?

CHP-A2: No. If a student successfully completes all clock    hours in a program prior to the normal number of weeks elapsing, the student    is not considered a withdrawn student and no proration of Title IV aid    received has to occur.

Students progress individually through clock hour programs.    and though an institution is required to calculate and report to the    Department the number of weeks of instruction in a clock hour program, those    weeks are an estimate of how long it normally takes the majority of students    enrolled in that program to complete the program of study. Therefore, it is    not uncommon for some students to complete a program somewhat earlier or    later than the reported weeks. However, the number of clock hours that make    up a program of study are the same for all students.

Of course, if a majority of students are completing the    program in fewer weeks than the number that is reported to the Department on    the institution’s Eligibility and Certification Approval Report (ECAR), the institution    must review and adjust the number of weeks it normally takes the majority of    their full-time students to complete the program of study. As a reminder, if    a student successfully completes all of the hours in the program before    completing a sufficient number of weeks of instruction to enter the final    payment period, the student will not qualify for any Title IV disbursements    for that final payment period. [Guidance issued 08/20/2021]

CHP-Q3: How should an institution treat hours of excused absences    when a student is permitted to graduate before successfully completing all of    the clock hours in a program?

CHP-A3: If an institution has an excused absence policy that    meets the Department’s requirements under 34 CFR 668.4(e), clock hours    associated with excused absences are considered successfully completed for    Title IV purposes. If a student has successfully completed 100 percent of a program’s hours, factoring in any allowable excused absences, no re-proration    of Title IV aid would be required since the student would be considered to    have completed all of the clock hours in the program of study for Title IV    purposes. [Guidance issued 08/20/2021]

CHP-Q4: In some situations, students will be permitted to graduate before successfully completing all of the clock hours in the program    after the point at which the student was scheduled to complete at least 60    percent of the payment period or period of enrollment. In these situations, can    the institution choose not to apply the R2T4 exemption and perform the R2T4    calculation instead? 

CHP-A4: No. The regulations at 34 CFR 668.22(a)(ii)(A)(1)    specifically state that a student who completes all the requirements for    graduation from his or her program before completing the days or hours in the    period that he or she was scheduled to complete is not considered to have    withdrawn. An institution may not apply the R2T4 requirements to a student who,    under the regulations, is not considered to be a withdrawn student for Title    IV purposes. Instead, the institution must recalculate the student’s    eligibility for Title IV aid based on enrollment in a program that includes a    smaller number of clock hours, as described in CHP-A1. [Guidance issued 08/20/2021]

**Scheduled Days in a Payment Period for a Program Offered in    Modules (SD)**

SD-Q1: A student enrolls in two 30-day modules in a term, but    does not enroll in any full-term courses. The student completes (but fails)    the first module, then begins attendance in the second module, but    subsequently withdraws before completing it. There is a four-day break    between the modules during which the student was not enrolled in any classes.    Is this scheduled break included in the calculation?

SD-A1: Yes. Because the student attended both modules, the    days in both modules would be included in the total number of days in the    payment period. For this student, there was also a short break of four days    between the two modules when the student was not enrolled in any other    courses. However, only scheduled breaks of at least five scheduled days or    breaks between modules that consist of five or more consecutive days during    which a student is not enrolled in other courses are excluded from the R2T4    calculation.

Therefore, because the number of consecutive days between    modules for this student is fewer than five, those days would be included in the    R2T4 calculation. The denominator of the calculation for this student would    include 64 days. [Guidance issued 08/20/2021]

SD-Q2: How does an institution determine whether the days in a  module are included in the R2T4 calculation? Are there differences based on whether the  institution uses an R2T4 Freeze Date? 

SD-A2: The answer depends on whether the institution uses an R2T4  Freeze Date (see RCFD-A1 for additional explanation of the R2T4 Freeze Date)  and the type(s) of Title IV aid for which the student is eligible during the  payment period or period of enrollment. 

When a student enrolls in a module during a payment period or  period of enrollment, the following guidance applies to all courses the student  enrolls in including full-term courses during the period. 

If the institution  uses an R2T4 Freeze Date, the days in a module/course are included in the R2T4  calculation if the student attends the module/course or is enrolled in the  module/course on the R2T4 Freeze Date. However, if a student is enrolled in a  period and the institution uses an R2T4 Freeze Date and the student withdraws  prior to the R2T4 Freeze Date, the institution includes the days associated  with any module/course the student started and any module/course the student  was enrolled in for the period as of the withdrawal date. 

If the student is only eligible for Pell Grant, Iraq-Afghanistan  Service Grant, and/or TEACH Grant funds during the period and the institution  does NOT use an R2T4 Freeze Date, the days in a module/course must be included  in the denominator of the R2T4 calculation only if the student actually attends  the module/course. This is because Pell Grant, Iraq-Afghanistan Service Grant,  and TEACH Grant recalculation requirements ultimately require institutions to  exclude from consideration in the student’s enrollment status any coursework  that the student did not attend.

If the student is eligible for Direct Loan or FSEOG funds during  the period (regardless of eligibility for other Title IV programs) and does NOT  use an R2T4 Freeze Date, the days in a module/course must be included in the  R2T4 calculation if the student was enrolled in the module/course on the first  day of the period or enrolled in the module/course at any time during the  period. This is because a student’s cost of attendance for these programs is affected  by the student’s enrollment in all modules during a payment period or period of  enrollment. [Guidance issued 08/20/2021 - archived;** **revised  09/03/2021 - archived;** **revised 10/06/21 - archived**; revised  11/24/21**]

SD-Q3: A student who is eligible for only Direct Loan funds    enrolls in Modules A, C, and D. The student completes Module A. While    attending Module C, the student drops all classes in both Modules C and D on    the same day. Which days are included in the enrollment period?

SD-A3: The institution must include the days in Modules A, C,    and D in the R2T4 calculation because the institution does not use an R2T4    Freeze Date, the student was eligible for Direct Loan funds, and the student was    enrolled in all three of those modules during the period. The denominator of    the calculation would include 90 days. [Guidance issued 08/20/2021]

SD-Q4: A student who is eligible for only Pell Grant funds is    enrolled in Modules A and B on the institution’s Pell Grant recalculation    date, resulting in a half-time Pell Grant enrollment status for the period. The    student completes Module A, but drops Module B before it begins while simultaneously    registering for Modules C and D. The student subsequently completes (but fails)    Module C and attends Module D, but withdraws halfway through that module. The    student attended coursework comprising three-quarters-time enrollment, but    the Pell Grant disbursement is based on a half-time enrollment status due to    the student’s enrollment on the Pell Grant recalculation date. Which days are    included in the R2T4 calculation?

SD-A4: The institution must include the days from Modules A, C,    and D because the institution does not use an R2T4 Freeze Date, the student    was eligible for only Pell Grant funds (and not Direct Loan or FSEOG) and the    student attended those modules. The institution would not include the days in    Module B because the student never attended Module B. The denominator of the    R2T4 calculation would include 90 days.

Note that, for purposes of determining the days to include in    the R2T4 calculation, the fact that the student was only considered to be enrolled    half-time for Pell Grant purposes due to the student’s enrollment on the Pell    Grant recalculation date is irrelevant. [Guidance issued 08/20/2021]

SD-Q5: A student who is eligible for both Pell Grant and Direct    Loan funds enrolls in Modules A and B. The student attends Module A, but in    the middle of that module, the student drops Module B. The student registers    for Modules C and D at the same time Module B is dropped. The student then    successfully completes Module A, but because that module includes less than    49 percent of the days in the payment period, the student does not qualify    for the withdrawal exemption. The student does not ultimately attend either    Module C or Module D, and is therefore considered withdrawn. Which modules    are included in the R2T4 calculation? 

SD-A5: The institution must include the days from Modules A,    B, C, and D in the R2T4 calculation because the institution does not use an    R2T4 Freeze Date, the student was eligible for Direct Loan funds (in addition    to Pell Grant funds), and the student was enrolled in all four of those    modules during the period. The denominator of the R2T4 calculation would    include 120 days. [Guidance issued 08/20/2021]

**R2T4 Calculation Freeze Date (RCFD)**

RCFD-Q1: Is an R2T4 Freeze Date different from a Pell    recalculation date?

RCFD-A1: Yes. An R2T4 Freeze Date is an optional (not    required) policy that uses the student’s enrollment schedule at a fixed point    to determine the number of days the student is scheduled to attend during the    period for R2T4 purposes. A Pell recalculation date is an optional (not    required) policy of recalculating an award if a student’s enrollment status    changes within a term. These are two separate concepts, and though the two    dates may be the same, they are used for different purposes. The R2T4 Freeze    Date can coincide with other dates (e.g. census dates, Pell recalculation    dates, etc.) or be a separate date. Similar to Pell recalculation dates, institutions    may use multiple R2T4 Freeze Dates for multiple modules. [Guidance issued 08/20/2021]

RCFD-Q2: Can you apply the R2T4 Freeze Date to some students    and not to other students within the same program?

RCFD-A2: No. An  institution’s R2T4 Freeze Date policy must be applied consistently to all  students in the same program. However, an institution is permitted to update  its R2T4 policy, including its R2T4 Freeze Date, for a payment period or period  of enrollment that has not yet begun, ensuring that all students within the  period are treated the same.  An  institution is not permitted to update its R2T4 Freeze Date policy during a  period thus creating a situation where students in the same program are being  treated differently within the same period. [Guidance issued 08/20/2021 -  archived, **revised 10/06/21**]

RCFD-Q3: Can an attendance-taking institution use the R2T4    Freeze Date as a student’s withdrawal date or are we required to use the last    day of attendance?

RCFD-A3: At an institution that is required to take    attendance, a student’s withdrawal date is always the last date of attendance    as determined by the institution from its attendance records. The R2T4 Freeze    Date is never used as the basis for a withdrawal date; it is only used to    determine the total number of days in the payment period or period of    enrollment (i.e., the denominator of the R2T4 calculation). [Guidance issued 08/20/2021]

RCFD-Q4: Are there any restrictions on when an institution can    set the R2T4 Freeze Date? 

RCFD-A4: When establishing an R2T4 Freeze Date, an institution    must ensure that the R2T4 Freeze Date for a given payment period or period of    enrollment will not occur prior to the timeframe when most students enroll    for classes for the period. An institution is not permitted to structure the    timing of students’ enrollment such that students can only enroll in a single    module when the R2T4 Freeze Date occurs but then enroll in other modules and    receive more Title IV aid after the R2T4 Freeze Date. 

If the Department determines that an institution has    structured its enrollment and R2T4 Freeze Date for a period in this manner,    we will require the denominator of all R2T4 calculations for that period to    incorporate all changes to Title IV enrollment. [Guidance issued 08/20/2021]

RCFD-Q5: If an institution chooses to use an R2T4 Freeze Date,    is it required to use an R2T4 Freeze Date for every payment period or period    of an enrollment? 

RCFD-A5: The R2T4 Freeze Date is optional. An institution is    not required to implement a R2T4 Freeze Date for programs offered in modules.    However, if an institution implements an R2T4 Freeze Date in one or all    modules in a payment period or period of enrollment, the policy should be consistent    across all payment periods or periods of enrollment in the program in those    periods that contain modules. For example, if an entire program contains    modules in each payment period, the institution cannot alternate between having    an R2T4 Freeze Date in one period and not having an R2T4 Freeze Date in the    subsequent period. [Guidance issued 08/20/2021]

RCFD-Q6: If an institution maintains multiple R2T4 Freeze    Dates to coincide with multiple modules, is the R2T4 Freeze Date that applies    to a student the one associated with the last class in which the student    enrolls and attends?

RCFD-A6: Yes. Like multiple Pell recalculation dates, a    student will only have one R2T4 Freeze Date apply to them within a payment    period or period of enrollment. The institution will use the last R2T4 Freeze    Date in the period that applies to a student. And, like Pell recalculation    dates, an R2T4 Freeze Date applicable to a particular module is applicable    only if the student actually starts attending that module. However, remember    that if a student attends one day in a module, the days in that module must    be included in the R2T4 calculation regardless of whether or not that course    has been dropped by the student’s latest R2T4 Freeze Date. [Guidance issued 08/20/2021]

**Institutional Charges (INST)**

INST-Q1:    On some occasions, even if a student attends a module and subsequently    withdraws before completing more than a week, our institution will refund all    tuition charges for that module. Does the tuition refund for the module    affect whether the days in the module are included in the R2T4 calculation?

INST-A1:    No. Whether an institution cancels or refunds tuition charges for a module    does not impact whether the days in that module are included in the R2T4    calculation. The institution would still include the days in the module for    which tuition charges were refunded in the R2T4 calculation. In this case,    the days in the module would be included in the R2T4 calculation because the    student attended at least one day in the module. 

The    R2T4 regulations do not prohibit an institution from developing its own    tuition refund policy. However, the institution must comply with refund    policies required by a state or other outside agencies. Although an    institution, State, or accrediting agency refund policy will determine the    charges a student will owe after withdrawing, those policies will not affect    the amount of Title IV aid the student has earned under the R2T4 calculation.    [Guidance issued 08/20/2021]

INST-Q2:    For purposes of determining the amount of institutional charges to include in    Step 5 of the R2T4 calculation, do we only include the charges for the    modules that are included in the calculation? Our institution charges at the    beginning of a payment period for all modules.

INST-A2:    For purposes of determining the amount of institutional charges to use in the    R2T4 calculation, an institution must always use the initial charges assessed    the student for the entire payment period or period of enrollment. An    institution only accounts for adjustments to those charges made prior to the    student’s withdrawal (for example, for a change in enrollment status    unrelated to the withdrawal). This also applies to situations where the    institution charged the student for classes in multiple modules, but the    denominator of the R2T4 calculation only consists of the days in a single    module. [Guidance issued 08/20/2021]

 

 

 

 

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