Return of Title IV Funds (R2T4)
Title IV funds are awarded to a student under the assumption that the student will attend school for the entire period for which assistance was awarded. Under the Return of Title IV (R2T4) regulations, a student is considered to have withdrawn from a payment period or period of enrollment if they do not attend all of the days in the payment period they were scheduled to
complete. Students “earn” Title IV aid that has been awarded in direct proportion to the number of days of the payment period (semester) they remain enrolled, beyond the 60% point in the semester. A student who withdraws after the 60% point earns 100% of the aid awarded for that term.
Effective July 1st, 2021, ED issued new guidance pertaining to R2T4 exemptions for modules.
If a recipient of FSA grant or loan funds withdraws from school after beginning attendance during a semester, the college must calculate the amount of assistance the student earned. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned (refer to the R2T4 manual for further details). If the amount disbursed to the student is less than the amount earned, then the student is eligible to receive a post-withdrawal disbursement (PWD).
If the student has received excess funds that must be returned to ED, the college shares the responsibility of returning those excess funds with the student. The college’s portion of the excess funds to be returned is equal to the lesser of the entire amount of the excess funds, or the student’s total tuition and fee charges multiplied by the percentage of unearned funds. If the college is not required to return all of the excess funds, the student may be required to return a portion of the remaining amount. The college must return its share of unearned funds to ED through the Office of Treasury Management (OTM). The student may repay their share to the college or, if the overpayment has been referred to NSLDS, make arrangements to repay ED directly.
New Return to Title IV Waiver and COD Corona Virus Indicator (CVI)
As noted in a May 15, 2020 Electronic Announcement posted on the Information for Financial Aid Professionals (IFAP) website, the CARES Act waives Return of Title IV Funds (R2T4) requirements for students whose withdrawals were related to the novel coronavirus disease (COVID-19) and provides that, for those students:
· Direct Loan funds received for the period will be cancelled,
· The period will not count toward the student’s Subsidized Loan usage for purposes of the 150% Direct Subsidized Loan Limit (SULA),
· Pell Grant funds received for the period will be excluded from the student’s Lifetime Eligibility Used (LEU).
The CARES Act requires schools to report to ED information specific to each student for whom it was not required to return Title IV funds under the waiver exception (and for each student for which Title IV funds were previously returned and are now being redrawn). The law also requires schools to report to ED the total amount of Title IV grant or loan assistance that was not returned as a result of the CARES Act provisions.
ED implemented a COD System functionality to support the requirements for the CARES Act in two phases. First phase was implemented on August 2, 2020. Second phase implemented in late September. More information can be found at May 15, 2020 Electronic Announcement
A disbursement flagged with the Coronavirus Indicator will also trigger the following actions:
· For Pell Grant disbursements, ED will adjust the LEU for the percentage represented by
the flagged disbursement(s). Once the adjustment is made, it will be viewable on the LEU History page and will be identified by the “Disaster Relief” Adjustment Type.
· For Iraq and Afghanistan Service Grant disbursements, ED will adjust the LEU through a manual process as there is no automated restoration of LEU for these grants. In addition, the detailed LEU adjustment will not be viewable on the LEU History page.
· For Direct Loan disbursements, ED will remove the flagged disbursement from the annual loan limit and Subsidized Usage calculations (this may include systematically changing the Financial Award period start and end dates), and ED will notify the appropriate federal loan servicer that the disbursement(s) has been discharged.
· For TEACH Grant disbursements, ED will remove the flagged disbursement from the TEACH Grant award limits, and ED will notify the TEACH Grant servicer that the disbursement has been cancelled.
When applicable, deobligations for Potential Over award Process (POP) situations will not occur for Pell Grant or Iraq and Afghanistan Service Grant awards with a flagged disbursement. Schools will still see POP edits and the awards will still appear on POP reports and Multiple Reporting Records (MRRs). If a disbursement is not flagged with the Coronavirus Indicator, the COD System will process the disbursement under existing business rules. The Coronavirus Indicator is not a required data element and can be blank if it is not applicable.
Once the Coronavirus Indicator is set and accepted by the COD System, a school will not be able to submit any further maintenance on that disbursement record. In addition, once the Coronavirus Indicator is set, it cannot be “unchecked.”
NOTE: If changes need to be made then the school can submit a ticket to COD.
Eligible Student
The student must be eligible to receive federal funds prior to the date of withdrawal. The conditions that make a student eligible for a “late disbursement” of Title IV funds must be met in order for Title IV aid to be considered “aid that could have been disbursed” and included in the R2T4 calculation. It is prohibited to award additional Title IV aid after the student has withdrawn. The exception to this rule is when students are within the 120-day deadline to complete verification (except Direct Loans, which cannot be awarded after the last day of enrollment).
Determining Student’s Withdrawal Date
The R2T4 process cannot occur until the college learns that the student has completely withdrawn. The date the college determines the student withdrew (also referred to as the “date of determination”) captures the point in time when the college could reasonably have been expected to know that a student withdrew.
· For official withdrawals, this date is either the date the student began the withdrawal
process or the date of their withdrawal notification.
· For unofficial withdrawals, this date is the date the college becomes aware that the student is no longer in attendance (usually after the end of the semester). NOTE: For a student who withdraws without providing notification to the school, the school must determine the withdrawal date no later than 30 days after the end of the earlier of (1) the payment period or the period of enrollment (as applicable), (2) the academic year, or (3) the student’s educational program.
· At CUNY, the institutional determination date for these calculations is 21 days from the end of the term.
· In the case of a student who stops attending after rescinding a withdrawal, the withdrawal date is the date the college becomes aware that the student did not or will not be able to complete the semester (usually reverts to the original withdrawal date). (Refer to “Rescinding Withdrawal” section below for more details)
Note: The college must document a student’s withdrawal date and maintain the documentation.
The date of determination is used to determine the following R2T4 deadlines:
· The college must perform an R2T4 calculation within 30 days.
· The college must disburse grant funds within 45 days to the student (written acceptance by the student is not required for post-withdrawal
disbursements of grant funds).
· The college must notify a student if a grant overpayment is due within 30 days.
· A post-withdrawal disbursement of loan funds must be offered to the borrower within 30 days.
· The college may disburse loan funds no later than 180 days from the date of determination if the borrower accepts the offer of all or a portion of a post-
withdrawal disbursement of loan funds (written acceptance by the borrower is required for post withdrawal disbursements of loan funds).
· The college must return the amount of Title IV funds for which it is responsible no later than 45 days from the date of determination.
The types of withdrawal and the corresponding withdrawal trigger date are summarized in the Return of Title IV Funds – Determining Trigger Dates chart.
Official Withdrawals (W)
When a student officially withdraws, the college may use any one of the following dates that best represents the student’s last date of attendance:
· Date student began the withdrawal process prescribed by the college
· Date student provided official notification
· Last date of attendance at an academically related activity as documented by the College
Administrative Withdrawals (WA)
If a school administratively withdraws a student who has not notified the school of their intent to
withdraw, the last possible date of withdrawal for the student is the date the school terminates the
student’s enrollment. Other examples of administrative withdrawal may include:
· Expulsion
· Suspension
· Cancellation of registration
· Failure to comply with immunization & Vaccine requirements
o MMR
o SARSCOV-2 (COVID-19) - Effective fall 2021
Rescinding Withdrawal
A college may allow a student to rescind a notification of withdrawal. The student must give written notice that they are continuing in academic activities and that they intend to complete the semester. This rescission would be negated if the student subsequently ceases attendance prior to the end of the semester. In this instance, the student’s withdrawal date would revert to the original date of notification (unless the college can document student’s later attendance at an academically-related activity). The college must have a formal published policy on rescinding withdrawals.
Determining the Amount of Aid the Student Earned
The semester begins on the first day of class and ends on the last day of final exams. Any scheduled breaks of five consecutive days or more should be excluded from the count of days. The amount of aid a student has earned is determined by dividing the number of days that the student attended by the number of days in the semester, then multiplying the result by the amount of federal aid the student “could have been disbursed”. This amount is compared to the amount of aid the student actually was disbursed to determine whether FSA funds must be returned or whether the student will receive a post withdrawal disbursement.
Aid That Could Have Been Disbursed
The calculation of earned Title IV program assistance includes all Pell Grant, Iraq & Afghanistan Service Grant, TEACH Grant, FSEOG, and Direct Loan funds that were disbursed or could have been disbursed to a student. Federal Work-Study (FWS) funds are not included in the calculation.
For purposes of determining earned Title IV aid, the college includes as “aid that could have been disbursed” any undisbursed Title IV aid for the period for which the return calculation is performed, as long as the conditions for late disbursements in 34 CFR 668.164(g)(2) were met prior to the date the student became ineligible. This is true regardless of whether the college was prohibited from actually making the disbursement on or before the day the student withdrew, as long as the conditions for late disbursements listed below are met prior to withdrawal.
The conditions for a late disbursement that must be met before the date the student became ineligible are:
· The Department processed a Student Aid Report (SAR) or Institutional Student Information Record (ISIR) with an official Expected Family Contribution
(EFC) for the student (except in the case of a PLUS Loan).
· For a Direct Loan, the college originated the loan.
· For a FSEOG, the college made the award to the student.
NOTE: A promissory note must be signed for a loan to be included as aid that could have been
disbursed in an R2T4 calculation. The signature may be obtained after the student withdraws but
the note must have been completed before the school performs the calculation (see DCL GEN-05-
16 published October 27, 2005 for more information).
Some funds included in “aid that could have been disbursed” are funds that the student may not actually be eligible to receive. Specific examples of “aid that could have been disbursed” that would not be offered as a post-withdrawal disbursement are:
· Second or subsequent disbursements of Direct Loan funds.
· If a student who has withdrawn did not begin attendance in enough courses to establish a half-time enrollment status, the school may not make a first disbursement of a Direct Loan to the student after the student withdraws. However, the funds are included as aid that could have been disbursed in the Return calculation.
· A disbursement of a Direct Loan to a first-year, first-time borrower who withdraws before the 30th day of the student’s program of study (except when this delay does not apply because of low default rates).
NOTE: If there is a disbursement of excess Pell Grant funds based on enrollment in classes for which non-attendance dates were subsequently reported, the school must:
· Recalculate the Pell enrollment status,
· Return the amount the student was overpaid, and
· Perform the R2T4 calculation based on the student’s correct Pell eligibility.
Crediting the Student’s Account
The college may credit the student’s account with Title IV grant funds from a post-withdrawal disbursement (PWD) without their authorization to satisfy current year tuition and fee or contracted room and board charges (incurred prior to withdrawal). Before crediting a student’s account with Title IV loan funds from a post-withdrawal disbursement to cover allowable charges, the college must obtain authorization from the student (or the student’s parent in the case of a PLUS Loan). The college must also have written authorization from the student (or the student’s parent in the case of a PLUS Loan) to credit the student’s account with Title IV loan funds from a post-withdrawal disbursement for other than the allowable current charges.
The school is not required to obtain confirmation from a student before making a post-withdrawal disbursement of Title IV grant funds. The PWD may be either credited to a student’s account to pay allowable charges or disbursed directly to a student without the student’s authorization.
College Return of Unearned Aid
The university must return unearned aid for which it is responsible to ED within 45 days (funds recorded as reconciled in the Federal Grant Payment System, G5) of the college determining the date of withdrawal. The college’s portion of the excess funds to be returned is equal to either the entire amount of the excess funds disbursed, or the total tuition and fee charges multiplied by the percentage of unearned funds, whichever is less.
Student Return of Unearned Aid
The student is assumed to have possession of Title IV funds only if the amount of disbursed Title IV funds exceeds institutional charges. The student’s share of unearned aid that must be returned is derived by subtracting the college’s share from the total unearned amount. Any loan funds that the student must return are repaid according to the terms of the promissory note. Grant funds in excess of $50.00 that the student must return are regarded as an overpayment. Under the HERA, the amount of a grant overpayment due from a student is limited to the amount by which the original grant overpayment amount exceeds half the total Title IV grant funds received (or that could have been received) by the student.
The student who owes a grant overpayment due to a withdrawal retains Title IV eligibility for a maximum of 45 days from the earlier of the date the college sends the student notice of the overpayment, or the date the school was required to notify the student. If the student repays in full or enters into a repayment agreement with either the school or ED within 45 days, the student retains eligibility. If the student fails to take action to resolve the overpayment within the 45 days, the school must report the overpayment to NSLDS immediately after the 45 days has elapsed and must refer the overpayment to ED’s Debt Collection Service (DCS) in accordance with instructions in the most recent FSA Handbook, Volume 5 “Over awards, Overpayments and Withdrawal Calculations”. Unresolved overpayments not referred to DCS ultimately become the school’s responsibility to repay.
Order of Return of Title IV Funds
Amounts returned to ED must be credited to the FSA programs in the following order:
· Unsubsidized Federal Direct Loans
· Subsidized Direct Loan
· Federal Direct PLUS Loan
· Federal Pell Grant
· Iraq & Afghanistan Services Grant
· FSEOG
· TEACH Grants
Post-Withdrawal Disbursement (PWD)
If a student has received less Title IV funds than earned, the student must receive a post withdrawal disbursement of any grant funds refunded to the student within 45 days from the date of determination. The school is not required to obtain written confirmation from the student for acceptance of a post-withdrawal disbursement of grant funds.
The college must notify the student in writing within 30 days of the college’s determination of withdrawal prior to making a post-withdrawal disbursement of loan funds. The notification must:
· Identify the type and amount of the loan funds
· Ask whether those loan funds are to be credited to the student’s account or disbursed directly to the student (or parent if applicable)
· Include the information necessary for the student, or the student’s parent in the case of a PLUS Loan, to make an informed decision as to whether the student or parent would like to accept any disbursement of loan funds
· Request confirmation of any post-withdrawal disbursement that the student or parent, as applicable, wishes the school to make.
The school must document the result of the notification process and the final determination made concerning the disbursement, in addition to maintaining that documentation in the student’s file. Once a school has received confirmation from a student, or the student’s parent in the case of a PLUS Loan, that they want to receive the post-withdrawal disbursement of loan funds, a school must make the post-withdrawal disbursement of Title IV loan proceeds as soon as possible, but no later than 180 days after the date of the school’s determination that the student withdrew.
Verification Not Completed Before Withdrawal
A school must offer any post-withdrawal disbursement of loan funds within 30 days of the date of the school’s determination that the student withdrew. The school must return any unearned funds
within 45 days. A school must make a post-withdrawal disbursement of grant funds within 45 days of that date of determination.
Schools must disburse any Title IV grant funds within 45 days of making a withdrawal determination, and disburse any loan funds the student accepted within 180 days. If verification is not completed in time for the school to meet the 45-day R2T4 deadline, the school should include in the R2T4 calculation only the Title IV aid that was not subject to verification (PLUS and unsubsidized loans).
If the student completes verification after the initial R2T4 calculation but within the 120-day verification extension deadline, the school must perform a new calculation and make the appropriate return or post-withdrawal disbursement. The post-withdrawal disbursement must be made within 180 days after the student’s last date of attendance in the semester the withdrawal occurred.
If the student fails to provide all required verification documents in time for the school to meet the 45-day return deadline, the school must return any Title IV funds disbursed on an interim basis.
R2T4 Treatment for Students Called to Active Duty
Provisions of the Higher Education Relief Opportunities for Students (HEROES) Act of 2003
now codify treatment of Title IV eligible students who must withdraw from school because of active duty service during a war, other military operation or national emergency; or qualifying National Guard duty during a war, other military operation or national emergency; or who reside or are employed in an area that is declared a disaster area by any Federal, State or local official in connection with a national emergency; or who suffered direct economic hardship as a direct result of war, other military operation or national emergency, as determined by the Secretary of Education. Under the HEROES Act, effective December 12, 2003, the school must perform an R2T4 calculation for students who withdraw due to their status as an affected individual. If these calculations result in the school being required to return funds to one or more of the Title IV programs, it must do so as it would for any student who completely withdraws. However, for these students, the school is to exclude from the student’s total institutional charges those amounts covered with non-Title IV sources of aid, such as tuition covered by a NYS TAP grant.
If these calculations result in an overpayment that is the student’s responsibility to repay, they are not required to return or repay the overpayment. Consequently, the school should not contact the student for repayment or report the student as an overpayment to NSLDS. However, the school must document in the student’s file the amount of any overpayment as part of the school’s documentation of the applicability of this waiver.
If an affected student is entitled to a post-withdrawal disbursement, the school must offer a minimum 45 calendar days for the student to respond to a school’s notification of their eligibility for the disbursement (the usual deadline is 14 days). However, the school can choose to extend the deadline up to 180 days.
The HEROES Act encourages schools to provide a full refund of tuition, fees, and other charges for the portion of the instruction period an affected student could not complete, or for which they did not receive academic credit. The CUNY Tuition and Fee Manual, Section V. Student Liability, part D. Reduction of Liability recommends a reduction of liability, whether or not it results in any refund, may be granted if a withdrawal from a course due to formal notification of military services during the semester, is provided for which the student did not qualify to receive an earned grade. Any such request must be documented for consideration. NOTE: No refund can be made to a student who has been assigned an earned grade, regardless of whether the grade is passing or failing. More information for the HEROES ACT can be found here.
Withdrawal date when a student dies
As a non-attendance institution, the college must determine the withdrawal date for the student under 34 CFR 668.22(c)(1)(iv). This section provides that if the college determines that a student did not begin its withdrawal process or otherwise provide official notification of their intent to withdraw because of illness, accident, grievous personal loss or other such circumstances beyond the student’s control, the withdrawal date is the date that the college determines is related to that circumstance. The withdrawal date can be no later than the date of the student’s death. The college must maintain the documentation it received that the student has died.
When a student receiving Title IV aid dies during the payment period or period of enrollment When the college determines that a student has died during a period, it must perform a Return calculation. If the Return calculation indicates that an institution is required to return Title IV funds, the school must return the Title IV funds for which it is responsible. The student’s estate is not required to return any Title IV funds disbursed to the student, nor is the college required to pay a PWD to the student’s estate. Therefore, an institution should neither report a grant overpayment for a deceased student to NSLDS, nor refer a grant overpayment for a deceased student to Debt Resolution Services.
If the college had previously reported a grant overpayment for a student who is deceased to Debt Resolution Services, it should inform Debt Resolution Services that it has received notification that the student is deceased. The regulations governing the Direct and Federal Perkins Loan programs provide for a discharge of a borrower’s obligation to repay a Federal Direct or Federal Perkins Loan if the borrower dies (including a Direct PLUS Loan borrower’s obligation to repay a Direct PLUS Loan if the student on whose behalf the parent borrowed dies).
If the college is aware that a student who has died has any outstanding Title IV loan debt, the school should contact the student’s estate and inform it of the actions it can take to have the student’s Title IV loan debt cancelled. If a Title IV credit balance created from funds disbursed before the death of the student exists after the completion of the Return calculation and the institutional refund calculations, the institution must resolve the Title IV credit balance in one of the following three ways:
· In accordance with the cash management regulations, paying authorized charges at the institution (including previously paid charges that are now unpaid due to the Return of Title IV funds by the institution).
· Returning any Title IV grant overpayments owed by the student for previous withdrawals from the present school (the institution may deposit the funds in its federal funds account and make the appropriate entry in G5). If the institution has previously referred the grant overpayment to Debt Resolution Services, the institution should provide Debt Resolution Services with documentation that the student has died so that Debt Resolution Services can delete the overpayment from its records.
· Returning any remaining credit balance to the Title IV programs.
Consumer Information
The college must provide information about R2T4 when a student withdraws. This information must include the requirements for withdrawing from the college, as well as a summary of the requirements of 668.22 of the federal regulations.
For Further Guidance
For a more comprehensive treatment of the R2T4 regulations, readers should turn to the most recent FSA Handbook, Volume 5 “Over awards, Overpayments and Withdrawal Calculations”.
Here you will find extended discussion of each element of the R2T4 calculation with definitions, examples, worksheets, case studies and regulatory citations to assist in a better understanding of this process. Additional guidance can be found in Dear Colleague Letters GEN-04-03 (February 2004), GEN-00-24 (December 2000), and GEN-98-28 (November 1998). This guidance is easily referenced at https://fsapartners.ed.gov/sites/default/files/2022-2023/2022-2023_Federal_Student_Aid_Handbook/knowledge-center_fsa-handbook_2022-2023_vol5.pdf.