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.
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
Return of Title IV Funds - April 2024
Return of Title IV Funds - October 2023: Return of Title IV Funds
Return of Title IV Funds - March 2023
Must a Student Accept a Post-Withdrawal Disbursement In Writing?
Return of Title IV Funds Specialist Designation
Are We Required To Have a Written Policy For Withdrawals and Return of Title IV Funds?
Must We Complete Verification If the Student Is Selected After Withdrawal But There Is Pending Aid To Be Disbursed?
Pop Quiz - Is an R2T4 Calculation Required if the Student Withdraws After 60 Percent of the Term?
Are We Required To Redo an R2T4 Calculation If the Withdrawal Date Changes Retroactively Due To an Academic Appeal?
Return of Title IV Funds - September 2022
Return of Title IV Funds: To Freeze or Not to Freeze
How Do We Handle Withdrawal From One Program and Transferring Into a Different Version Of the Same Program That Has Modules?
Can We Round Clock Hours Up When Determining If the Student Completed the Payment Period?
What Is the Midpoint For an Unofficial Withdrawal From a Program Offered In Modules?
Return of Title IV Funds: 2022-23
Do We Include Institutional Charges For Multiple Modules Even If Only One Module Is Included In the R2T4 Calculation?
Is R2T4 Required If an Academic Program Is Paused Due To an Instructor's Unscheduled Vacation Or Employment Termination?
White House Extends Coronavirus National Emergency
Are We Required To Recalculate the Cost Of Attendance When a Direct Loan-Only Recipient Withdraws From Modules?
Pop Quiz - Must Students Who Fall Under the 49 Percent Exemption for R2T4 Receive Exit Counseling?
Which Is Best, an R2T4 Freeze Date or No R2T4 Freeze Date?
When Not Using an R2T4 Freeze Date, What Does "Eligible For" a Type Of Aid Mean?
If a Student Withdraws From Modules and Full-Term Courses, When Do We Begin Counting 45 Days For Attendance In a Later Module?
Pop Quiz - What Is the Order of Return of Funds From a Stale Dated Check?
Are Institutional Charges Impacted By Whether a Module Is Included In the R2T4 Calculation Denominator?
How Do We Determine Scheduled Days In the R2T4 Calculation Denominator When the Student Withdraws Before the R2T4 Freeze Date?
Does Enrollment In a Full-Term Course Affect the Number of Days In the R2T4 Calculation Denominator For a Program Offered In Modules?
Do the R2T4 Waiver and Withdrawal Benefits Apply For the 2022-23 Award Year and Beyond?
How Do We Report Post-Withdrawal Disbursements In Lump Sum Reporting for COVID-19 Related Withdrawals?
How Does a Long Break Between Modules Affect the 49% Calculation For R2T4?
If There Is Only One Module In a Period, Are All Other Days Excluded From the 49% Calculation For R2T4?
When Not Required To Take Attendance, Is the Date Of Determination the Same As the Official Withdrawal Date?
Pop Quiz – Has the Order of the Return of Title IV Funds Changed?
Are Undergraduate Courses Included In the R2T4 Calculation For a Graduate Student In a Non-Modular Program?
Can a Student Who Qualifies For An R2T4 Exemption Also Receive An R2T4 Waiver Under the CARES Act?
Is R2T4 Required If a Student Earns an "F" In the Only Module In Which He Was Enrolled For the Term?
How Do We Determine the Number Of Countable Days For the 49% R2T4 Exemption?
Does the R2T4 Exemption For Early Graduation Apply If the Student Retroactively Graduates From a Different Program?
For NSLDS Enrollment Reporting, How Do We Report a Student Who Qualifies For an R2T4 Exemption?
Can the School Choose Not To Apply the R2T4 Exemption If a Student Completes a Program Early and Graduates?
When Performing R2T4, How Long Do We Have To Determine If a Student Earned a Passing Grade In an Incomplete Course?
Do We Include a Module In the R2T4 Calculation If the Direct Loan Recipient Does Not Need the Module To Establish Half-Time Enrollment?
Do Multiple R2T4 Freeze Dates Function the Same As Multiple Pell Recalculation Dates?
Does Enrollment In a Full-Term Course Impact Counting Days In Modules For the 49% R2T4 Exemption?
Which Days Are Included In the R2T4 Calculation For Study Abroad, Consortium, and Contractual Agreements?
Is a Student Who Qualifies For an R2T4 Exemption Considered To Have Completed the Payment Period For Cash Management Purposes?
How Does Late Reporting Of Grades Affect R2T4 Processing Under the Rules Effective July 1, 2021?
If a Class or Module Starts Early Or Ends Later, Are the Extra Days Included In the R2T4 Calculation?
Does FWS Count When Determining the Percentage Of the Payment Period the Student Completed (R2T4 Denominator)?
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.
You must be logged in to comment on this page.