RETURN OF TITLE IV AID REGULATORY CHANGES 34 CFR 668.22 Final Regulation Published October 29, 2010...

RETURN OF TITLE IV AIDRETURN OF TITLE IV AIDREGULATORY CHANGESREGULATORY CHANGES

34 CFR 668.2234 CFR 668.22Final Regulation Published Final Regulation Published October 29, 2010October 29, 2010

OASFAADublin, OHMay 24, 2011

R2T4 – Current Definitions R2T4 – Current Definitions

Standard Terms◦ Semesters, trimesters – generally 14–17 weeks long◦ Quarters – generally 10–12 weeks long

Non-standard terms – where all coursework is expected to begin and end within a set period of time that is not a semester, trimester, or quarter terms

Non-terms – all clock hour programs and credit hour programs that do not begin and end within a set time (self-paced), where courses overlap, where sequential courses do not begin, and end within a term

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R2T4 – Current Definitions R2T4 – Current Definitions

“Week of instructional time”◦Any seven consecutive day period with at

least one day in which scheduled instruction or examination occurs

◦Does not include homework time, vacation time, orientation, or counseling

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““Offered in Modules”Offered in Modules”

If the student ceases attendance before the period for which aid was awarded, it is a withdrawal

The denominator of the return calculation includes the full number of weeks used to determine the aid award, absent any institutionally scheduled breaks of five or more consecutive days or periods of time that the student was on an approved LOA

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““Offered in Modules” - Example AOffered in Modules” - Example A Institution A:

◦ Fall and Spring = standard terms Never considered to be “offered in modules”

◦ Summer = three 5-week sessions (combined to be a standard term) Students can enroll in any of the summer sessions or all of

them Students enrolled in the 5-week summer sessions are

considered in programs “offered in modules” since none of the sessions span the entire length of the term (the 15-week period)

““Offered in Modules” - ExampleOffered in Modules” - ExampleAA

Jeff Enrolls in all three summer sessions and ceases enrollment on Day 5 in the first

5-week session

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““Offered in Modules” - ExampleOffered in Modules” - ExampleAAThe Results:

◦Step 1 – Recalculate Pell & Campus-based

◦Step 2 – Determine earned & unearned amounts of Title IV aid (TIV) Numerator = # of days attended in

Course 1 (assume no breaks) 5 days Denominator = Start date of Course 1

thru end date of Course 3 (less any scheduled break of 5 or more consecutive days or approved LOAs) 105 days or .048 or 4.8%

““Offered in Modules” - ExampleOffered in Modules” - ExampleAA

Session 15 weeks

Session 25 weeks

Session 35 weeks

35 days 35 days 35 days

Withdrawal Day 5 student also drops remaining sessions.

Institution Required to Take Attendance: WD = Day 5. Denominator = 105 days. Per GEN 04-12, the institution must have a process to make this determination no later than 14 days after the LDA.

Institution not Required to Take Attendance: WD = 668.22(c). Denominator = 105 days.

““Offered in Modules” - ExampleOffered in Modules” - ExampleBB

Summer sessions include three 5-week sessions and 15-week sessions

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Session5- week

Session5-week

Session 5-week

Session 15- week

LuGail enrolls in two 15-week courses – this student is not considered to be enrolled in a program offered in modules. .


Session5- week

Session5-week

Session 5-week

Session 15- week

Scott enrolls in one 5-week module and one 15-week course. H is considered to be enrolled in a program offered in modules.

Scott

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Theory Behind the CalculationTheory Behind the CalculationStudent earns Title IV aid through

attendance◦Percentage of aid earned is equal to the percentage of payment period or enrollment period completed

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Return Of Title IV FundsReturn Of Title IV FundsApplies only to Title IV eligible

students who begin attendance and then completely withdraw, or otherwise cease attending

If student enrolled but never attended any classes◦Student did not establish eligibility

for any funds◦All Title IV aid disbursed must be

returnedto the programs

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How Does It Work?How Does It Work?If school has disbursed more aid

than the student has earned, money is returned to the programs

If school has disbursed less aid than the student has earned, a post-withdrawal disbursement will be calculated

Effective Date Of New Effective Date Of New RegulationsRegulationsApplies to all students who withdraw

from payment period or period of enrollment that begins on/after July 1, 2011

DOES NOT APPLY TO CROSSOVER DOES NOT APPLY TO CROSSOVER PAYMENT PERIODS IN 2011PAYMENT PERIODS IN 2011

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Program DefinitionsProgram DefinitionsNew rules define a program

“offered in modules”◦ A course or courses in program do not span entire length of payment period or period of enrollment

Doesn’t matter what “modules” are called at the institution

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Credit Hour Programs Credit Hour Programs Offered In ModulesOffered In ModulesStandard term program “offered in

modules”◦Two 8-week sessions within a 16

week semester◦Three 5-week sessions within a 15

week semester◦Two 6-week sessions within a 12

week quarter◦Winter “inter-session” or “J term”

between fall and spring semesters

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Credit Hour Programs Credit Hour Programs Offered In ModulesOffered In Modules

• Student considered to be withdrawal if does not complete all days scheduled to complete within payment period/term

• School must document completed all courses with a passing grade

• If no passing grade in last scheduled course, school must demonstrate student completed period

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Student in modular program not considered a withdrawal if ◦Provides written confirmation of intent to

attend a future module in period of enrollment Must be provided at the time of withdrawal

◦Student may change return date in writing Must provide change prior to original return

date• Future module must begin within 45 calendar

days in a non-standard and non-term program19


Nonstandard & Nonterm Programs◦Student considered to be withdrawal if not scheduled to begin another course in period of enrollment for more than 45 calendar days 45 days measured from end of module ceased attending

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Clock Hour ProgramsClock Hour Programs

• Student considered to be withdrawal if does not complete all clock hours and weeks of instructional time that was scheduled to complete

• School must document completed all courses with a passing grade

• If no passing grade in last scheduled course, school must demonstrate student completed period

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Is Student A Withdrawal?1. Did the student cease to attend before completing or

fail to begin attendance in a course scheduled to attend? If yes, go to question 2. If no, student not a withdrawal

2. When ceased to attend or failed to begin attendance in a scheduled course, was the student attending other courses? If yes, student not a withdrawal If no, go to question 3

3. Did the student confirm attendance in a later module in the payment/enrollment period (45 day rule, if applicable)? If no, student is a withdrawal. If not a withdrawal, Pell recalculations may apply

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Return After WithdrawalReturn After WithdrawalModular term-based credit hour program

◦Withdrawn student may return to same program prior to end of payment period/period of enrollment Student eligible for any Title IV funds for

which eligible prior to withdrawalClock hour/nonterm credit hour program

◦Withdrawn student may return to same program within 180 calendar days Student eligible for any Title IV funds for

which eligible prior to withdrawal

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R2T4 Calendar Days R2T4 Calendar Days Modular ProgramsModular Programs

Total calendar days include all days on which the student was scheduled to attend◦Days of completed courses count if course

does not span length of term◦Exclude scheduled breaks of at least 5

consecutive days when student not scheduled to attend a module or other course offered during that period

For a withdrawn student who has made schedule changes ◦Do not count days of courses officially dropped

prior to complete cessation of attendance

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After Written Confirmation After Written Confirmation Of ReturnOf ReturnStudent considered to be

withdrawal if does not return as scheduled

Withdrawal dates back to time that confirmation originally provided◦Determine withdrawal date and days of attendance as if confirmation of future attendance never provided

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R2T4 & Taking AttendanceR2T4 & Taking AttendanceR2T4 calculates Title IV aid earned

based upon student attendance◦Aid prorated based upon days or hours student attended

Should use best information available to determine withdrawal date since it directly impacts dollars

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Required To Take AttendanceRequired To Take AttendanceSchool is required to take

attendance if◦Outside entity requires that attendance be taken OR

◦School has own requirement that instructors take attendance OR

◦Outside entity or school has requirement that can only be met by taking attendance or a comparable process

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Required To Take Required To Take AttendanceAttendanceIf required to take attendance—

◦For some students—use attendance records for those students

◦For a limited period of time—use attendance records for withdrawals during that limited period of time

◦On a specific date—NOT considered to be required to take attendance

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AttendanceAttendanceAttendance must be “academic attendance”

or “attendance at an academically-related activity”. Examples include◦ Physical class attendance where there is

direct interaction between instructor and student

◦ Submission of an academic assignment◦ Examination, interactive tutorial, or

computer-assisted instruction◦ Study group assigned by school◦ Participation in on-line discussion about

academic matters◦ Initiation of contact with instructor to ask

question about academic subject29

Questions????Questions????

Jamie A. Malone

Training Officer

U.S. Department of Education

312-730-1528

[email protected]

What did she say????

I was thinking.

.

Hmm

m

…

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Please provide any comments Please provide any comments to my supervisor-to my supervisor-

Jo Ann BorelTitle IV Training [email protected]

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RETURN OF TITLE IV AID REGULATORY CHANGES 34 CFR 668.22 Final Regulation Published October 29, 2010...

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