Pop Quiz – How Do Retroactive Withdrawals Affect the R2T4 Calculation?


The school allows for retroactive drops for courses in some situations. A student started the term, received a disbursement, and subsequently, the school retroactively withdrew the student from the term. How does this affect the R2T4 calculation?


The return of Title IV funds (R2T4) regulations do not recognize retroactive institutional refund policies. Please see the following excerpt from page 5-5 of the 2020-21 FSA Handbook: "The R2T4 regulations do not dictate an institutional refund policy. Instead, a school is required to determine the earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance or, in the case of a clock-hour program, was scheduled to be in attendance."

The R2T4 calculation is based on the amount of time the student actually spent in attendance. This speaks to the necessity of making cost of attendance adjustments and aid adjustments due to never attending courses before doing the R2T4 calculation. However, keep in mind that for Direct Loans, at the time of disbursement, you are only required to verify at least half-time attendance.

Student Aid Index: 

For additional information, try NASFAA's Student Aid Index. It is a central hub of all the important financial aid resources you need with direct links to legislation, regulation, Dear Colleague Letters, and other ED and NASFAA references. It is updated on a rolling basis with the latest news and changes. Search Return of Title IV Funds and Administrative Capability.


Publication Date: 11/30/2020

James C | 11/30/2020 8:16:23 AM

So this makes it sound that if the student was in 6 credits at the time of disbursement they keep the loan regardless of the back-dated withdrawal. I have received mixed responses from the Dep't of Ed on this subject when I have asked and answer needs a more thorough explanation with scenarios.

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