NASFAA has updated its return of Title IV funds (R2T4) decision trees to reflect the new rule in 34 CFR 668.22(a)(2)(ii)(A)(6), under which a student is not considered to have withdrawn if: 1) The institution’s records treat a student as having never attended courses for that payment period or period of enrollment; 2) The institution returns all the Title IV grant or loan assistance, including all Title IV credit balances provided to the student or parent, that were disbursed for that payment period or period of enrollment; 3) The institution refunds all institutional charges to the student for the payment period or period of enrollment; and 4) The institution writes off or cancels any payment period or period of enrollment balance owed by the student to the institution due to the institution’s returning of Title IV funds to the U.S. Department of Education (ED). Institutions are allowed to early-implement this new rule as of February 3, 2025. Whether the institution treats a student as having never attended courses with these conditions is optional. However, if the school implements this option, the student is not a withdrawal if all conditions are met.

The decision trees are available in the 2025-26 Return of Title IV Funds Self Study-Guide (available soon) and under Resources in the AskRegs Knowledgebase:

• R2T4 -- Decision Tree--Determining Whether a Student Has Withdrawn from a Nonterm or Subscription-Based Program [Updated 2025]
• R2T4 -- Decision Tree--Determining Whether a Student Has Withdrawn from a Standard- or Nonstandard-Term Program Offered in Modules [Updated 2025]
• R2T4 -- Decision Tree--Determining Whether a Student Has Withdrawn from a Standard- or Nonstandard-Term Program Without Modules [Updated 2025]

Publication Date: 4/3/2025