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Return of Title IV  Funds Q & A Program  Integrity Q&A
Questions on this topic are  
divided into the following categories: 
- **General Questions**
- **Programs Offered in Modules (Mod)**
- **Scheduled Days in a Payment Period for a Program Offered in Modules(SD)**
- **R2T4 Calculation Freeze Date (RCFD)**

**General Questions (R2T4)**

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

R2T4-A1: The changes to  §668.22, known as the Return of Title IV Funds regulations, apply to students  who withdraw from payment periods or periods of enrollment that begin on or  after July 1, 2011. This means that they do not apply to students who withdraw  from a 2011 crossover payment period that begins prior to July 1, 2011, even if  the student received Title IV, HEA program funds from the 2011-2012 award year  for that crossover payment period. [Guidance issued 7/20/2011] 

**Programs Offered in Modules  (MOD)**

 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: The total number of  calendar days in the period includes all days within the period that the  student was scheduled to complete prior to ceasing attendance, excluding days  in which the student was on an approved leave of absence and any 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. Adjustments  to a student enrollment status made after the student ceases attendance have no  bearing on the Return of Title IV Funds requirements. Thus, if the student  drops the classes in the two remaining modules after ceasing attendance, the  total number of calendar days in this student’s payment period or period of  enrollment would include the days in all three modules, except for any  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, and days in which the student was on an approved leave of absence.  However, if the student drops the classes in the two remaining modules prior to  ceasing attendance (which would necessitate a recalculation of the student’s  eligibility for Title IV, HEA program funds), the total number of calendar days  in the student’s payment period or period of enrollment would include only the  days in the first module, except for any scheduled breaks of at least five  consecutive days and days in which the student was on an approved leave of  absence. [Guidance issued 7/20/2011] 

MOD-Example—Program  Offered in Modules  Provided here is an example illustrating many of the changes to the regulations  addressing withdrawals from programs offered in modules. More detailed examples  will be provided in the 2011-2012 Federal Student Aid Handbook. 

Determination  of Withdrawal Questions As noted on page 66895 of the preamble to the final regulations, the following  three questions may be used to determine whether a student in a program offered  in modules is a withdrawal and the Return of Title IV Funds requirements apply: 

 Question  1: After beginning attendance in the payment period or period of enrollment,  did the student cease to attend or fail to begin attendance in a course he or  she was scheduled to attend?If the answer is no, this is not a withdrawal. If the answer is yes, go to  question 2. 

 Question  2: When the student ceased to attend or failed to begin attendance in a course  he or she was scheduled to attend, was the student still attending any other  courses?  If the answer is yes, this is not a withdrawal, however other regulatory  provisions concerning recalculation may apply. If the answer is no, go to  question 3. 

 Question  3: Did the student confirm attendance in a course in a module beginning later  in the period (for non-term and nonstandard term programs, this must be no  later than 45 calendar days after the end of the module the student ceased  attending)? 
  If  the answer is yes, this is not a withdrawal, unless the student does not  return. If the answer is no, this is a withdrawal and the Return of Title IV Funds  requirements apply. Example  This example illustrates: (1) how to determine when a student is a withdrawal  from a term-based program offered in modules; (2) the amount of aid to use in  the Return of Title IV Funds calculation when a student withdraws from a  program offered in modules; (3) how to determine the numerator and denominator  when calculating the percentage of the payment period completed for a student  who withdraws from a program offered in modules; and (4) what steps must be  taken when a student who withdrew from a term-based program offered in modules  returns within the payment period; (5) how to determine the numerator and  denominator when calculating the percentage of the payment period completed for  a student who withdraws again. 

 Program  Profile: Payment Period/Period of Enrollment: Payment period, 15-week semester  Program structure for payment period/period of enrollment: Three consecutive  five-week modules, 35 days in each module, no scheduled breaks 

 A  student enrolls for one three-credit course in each of the three modules.  Student ceases attending module 1 after completing 10 days. The student does  not confirm attendance in a later module. The student does not attend module 2,  but returns for the one 3-credit course in module 3. The student withdraws from  module 3 after completing 15 days. 

When  the institution determines that the student has ceased to attend module 1, the  institution answers the Determination of Withdrawal Questions to determine  whether the student is a withdrawal as follows: The  answer to Question 1 is yes. The student ceased to attend a course the student  was scheduled to attend—the three-credit course in module 1. Because the answer  to Question 1 is yes, Question 2 must be answered.   The  answer to this Question 2 is no. When the student ceased to attend the course  in module 1, he or she was not attending any other classes. Because the answer  to Question 2 is no, Question 3 must be answered.   The  answer to this Question 3 is no. The student did not confirm attendance in a later  module. Thus, this student is a withdrawal and the Return of Title IV Funds  requirements apply. 

If  the student was awarded Pell Grant funds, before performing the Return of Title  IV Funds calculation, the institution must recalculate the student’s awards to  reflect the change in enrollment status from nine credit hours, to three credit  hours. These recalculated aid amounts are used in the Return of Title IV Funds  calculation. 

The  percentage of the payment period completed is determined by dividing the number  of calendar days completed by the total number of calendar days in the payment  period, which included all days within the period that the student was  scheduled to complete, except for any 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, and any days the student was on an  approved leave of absence. The student has completed 10 days. The total number  of days in the payment period includes all the days in all the modules the  student was scheduled to complete, which is 105 days (three modules of 35 days  each). The percentage of the payment period completed is determined by dividing  10 days by 105 days, resulting in .0952, rounded to .095 or 9.50 percent. 

When  the student returns for module 3, §668.22(a)(2)(iii)(A) applies, which provides  that, if a student withdraws from a term-based credit hour program offered in  modules and reenters the same program prior to the end of the period, the  student is treated as if he or she did not cease attendance for purposes of  determining the student’s aid awards for the period. The student is considered  to be in the same payment period he or she was in at the time of the withdrawal  and retains his or her original Title IV eligibility for that payment period,  provided the student’s enrollment status continues to support the same amount  of those funds. To do this, the institution must: 

recalculate the student’s Title IV, HEA  program eligibility based upon enrollment in modules 1 and 3 and then  re-disburse any Title IV, HEA program funds that had been disbursed and then  returned under the Return of Title IV Funds provisions, adjusting, if  necessary, for the change in enrollment status from nine credit hours to six  credit hours; 

disburse any Title IV, HEA program funds  the student was otherwise eligible for that had not yet been disbursed at the  time the student withdrew, adjusting for the change in enrollment status; and 

cancel any Title IV overpayments assessed  the student as a result of the prior withdrawal that were disbursed upon  reentry. 

When  the institution determines that the student has ceased to attend module 3, the  institution again answers the Determination of Withdrawal Questions to  determine whether the student is a withdrawal: 
  The  answer to Question 1 is yes. The student ceased to attend a course the student  was scheduled to attend—the three-credit course in module 3. Because the answer  to Question 1 is yes, Question 2 must be answered.   The  answer to this Question 2 is no. When the student ceased to attend the course  in module 3, he or she was not attending any other classes. Because the answer  to Question 2 is no, Question 3 must be answered.   The  answer to this Question 3 is no. There are no later modules in which the  student can confirm attendance. Thus, this student is a withdrawal and the  Return of Title IV Funds requirements apply.   The  total number of days in the payment period is the original 105 days. While the  student did not begin module 2, since module 2 was included in the original  payment period or period of enrollment and used to determine the amount of  Title IV, HEA funds eligibility, the 35 days from module 2 are included in the  denominator.   The  total number of completed calendar days in the period reflects the completed  days in both modules 1 and 3. The student had completed 10 days in module 1 and  15 days in module 3 for a total of 25 days completed in the payment period. The  percentage of the payment period completed is determined by dividing 25 days by  105 days, resulting in .238, or 23.8 percent. [Guidance issued 7/20/2011]   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: Yes, the days in  modules two and three are included in the total number of calendar days in the  payment period or period of enrollment. This is the case whether the student  ceased attendance during the first module or completed the first module. As  noted in MOD-Q&A8, a student who ceases attendance between modules he or  she is scheduled to attend is considered to have withdrawn and a Return of  Title IV Funds calculation is required unless the student provides written  confirmation of future attendance in the payment period or period of  enrollment. However, as noted in MOD-Q&A9, adjustment to a student’s  enrollment status made after the student ceases attendance have no bearing on  the Return of Title IV Funds requirements. Thus, if a student drops all future  classes he or she was scheduled to attend in the period between modules when  the student is attending no other classes, the institution must perform a  Return of Title IV Funds calculation that uses the days in all three modules  for the period of enrollment unless the student provides written confirmation  of future attendance in the payment period or period of enrollment. This is the  case even if the class or classes are dropped by the institution, rather than  the student, during the period between modules (for example, because the institution  cancels the class or drops the student from the class because it determines  that the student’s grades in prior classes do not allow the student to progress  to that class). [Guidance issued 2/2/2012] 
 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 Return  of Title IV Funds purposes? 

MOD-A15: No. Classes  dropped on the same day that the student withdraws have no bearing on the  Return of Title IV Funds requirements. The institution must perform a Return of  Title IV Funds calculation that includes those classes in the days in all  modules the student was scheduled to attend. [Guidance issued 2/2/2012]

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, including the requirement that the student has completed  coursework comprising half-time enrollment during the period.

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]

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

  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. 

  If  the institution uses an R2T4 Freeze Date, the days in a module are included in  the R2T4 calculation if the student  attends the module or is enrolled in the module on the R2T4 Freeze 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 must be included in the  denominator of the R2T4 calculation only if the student *actually attends the module*. 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 must be  included in the R2T4 calculation if the  student enrolled in the module 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]

 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.

  If the institution uses an R2T4 Freeze Date, the days in a module are included in the R2T4 calculation if the student attends the module or is enrolled in the module on the R2T4 Freeze 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 must be included in the  denominator of the R2T4 calculation only if the student actually attends the module. 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 must be included in the R2T4 calculation if  the student enrolled or registered in the module at any time for 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;**revised 09/03/2021**]

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.

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]

**R2T4  Calculation Freeze Date (RCFD)**

  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 institutions R2T4 Freeze Date policy must be applied consistently to all  students in the same program. [Guidance issued 08/20/2021]
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