Return to Title IV Funds Policy

Applies only to the Return of Title IV (R2T4) requirements established by the federal government. The return of funds requirement is a complex process involving a great deal of interoffice cooperation.

Process Overview & Applicability

Title IV funds are awarded to a student under the assumption that the student will attend courses for the entire enrollment period for which the assistance is awarded. Students who do attend and successfully complete the entire enrollment period, are assumed to have ‘earned’ 100% of the Title IV funding disbursed. Schools are required to perform a Return of Title IV calculation for Title IV eligible students who do not successfully complete the entire enrollment period due to withdrawal (official or unofficial). If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. If the amount disbursed to the student is less than the amount the student earned, and for which the student is otherwise eligible, the student is eligible to receive a post-withdrawal disbursement of the earned aid that was not received. 

The Return of Title IV calculations are required when a student has failed, received an unsatisfactory grade or withdrawn, officially or unofficially, from any enrolled course during a period of enrollment at the college. Students, who fail to complete some courses, but not all enrolled courses, may be included in the Return of Title IV calculations. Title IV funds to be included in the calculation are: Unsubsidized and Subsidized Federal Direct Stafford loans, Federal Direct PLUS loans, Federal Pell Grant, Iraq and Afghanistan Service Grants, FSEOG, TEACH Grants (however Aims does not participate in TEACH). Note: Federal Work Study funds are not included in the calculation

1. Establishing a Withdrawal Date: When a student withdraws from a course or ceases to attend, they establish a withdrawal date at that time.
   1. Official Withdrawals - The withdrawal date is the date the student began the school’s official withdrawal process or officially notified the school of intent to withdraw. Students can withdraw from all courses online or in person with designated Aims Community College employees. When all courses receive a ‘W’, the withdrawal date is considered the date of initiation by the student or school as in the case of cancelled courses or student appeals.
   2. Unofficial Withdrawals - The last date of attendance for an unofficial withdrawal is the documented date recorded by the college or, if no date is available, the midpoint of the student’s term of enrollment. The last date of attendance is the last date a student participated in an academically related activity.
      1. Aims Community College procedure does not require its instructors to take attendance. Therefore, Aims Community College will use the standard 50% of the term as the last date of attendance (LDA) unless an actual date can be documented by the college. In the case of unofficial withdrawals, Aims Community College will use the later of the LDA or 50% point.
   3. A student is considered to have withdrawn from a payment period or period of enrollment if within that same payment period or period of enrollment the student does not complete all the days the student was scheduled to complete.
2. Withdrawal Dates for Courses Offered in Modules: If a student is enrolled in at least one module course, they are considered a module student and thus the following conditions apply. Colleges will be able to determine whether a student enrolled in a module(s) is a withdrawal by asking the following questions:
   1. Determining Whether a Student Has Withdrawn from a Standard- or Nonstandard-Term Program Offered in Modules:
      1. After beginning attendance in at least one course, did the student stop attending or fail to begin attendance in a scheduled course applicable to the student’s Title IV-eligible program of study?
         1. If YES- Proceed to number 2.
         2. If NO- Not a withdrawal.
      2. When the student stopped attending or failed to begin attendance in a scheduled course, was the student currently attending any other course(s) applicable to the student’s Title IV-eligible program of study in the payment period or period of enrollment?
         1. If YES- Student has made a schedule change, recalculate Title IV aid per applicable program regulations and school policies.
         2. If NO- Process to number 3.
      3. Did the student complete all requirements for graduation?
         1. If YES- Student had not withdrawn, may be required to recalculate Title IV aid per applicable program regulations and school policies.
         2. If NO- Proceed to number 4.
      4. Did the student successfully complete coursework applicable to the student’s Title IV-eligible program of study in one module or a combination of modules that equals 49% or more of the number of countable days in the payment period or period of enrollment?
         1. If YES- Student had not withdrawn, may be required to recalculate Title IV aid per applicable program regulations and school policies.
         2. If NO- Proceed to number 5.
      5. Did the student successfully complete coursework applicable to the student’s Title IV-eligible program of study equal to or greater than what the school considers to be half-time enrollment for the payment period or period of enrollment?
         1. If YES- Student had not withdrawn, may be required to recalculate Title IV aid per applicable program regulations and school policies.
         2. If NO- Proceed to number 6.
      6. Did the student confirm attendance in writing for a course applicable to the student’s Title IVeligible program of study in a later module in the payment period or period of enrollment that begins no later than 45 calendar days after the end of the module he or she ceased attending?
         1. If YES- Student has not withdrawn. No R2T4 calculation required unless the student fails to begin attendance in later module. It may be necessary to recalculate aid per applicable program regulations and school policies.
         2. If NO- Student has withdrawn. Perform R2T4 calculation. It may be necessary to first recalculate Title IV aid for courses the student never attended, per applicable program regulations.
3. Written Confirmation of Future Attendance
   1. A student is not considered to have withdrawn if the college obtains written confirmation from the student (close to the date that the student actually ceased attendance and before the time the college was required to return Title IV funds, offer any post-withdrawal disbursement of loan funds, or take any other action under the Return of Title IV requirements) that the student will attend a module that begins no later than 45 calendar days after the end of the module he or she ceased attending later in the same payment period or period of enrollment.
   2. A college may not wait to perform a Return of Title IV Funds calculation to see if the student who has withdrawn and has not provided written confirmation of future attendance will return later in the payment period or period of enrollment. Similarly, if a student withdraws from a term-based credit-hour program offered in modules during a payment period or period of enrollment and reenters prior to the end of the period, the student is eligible to receive any title IV program funds that they were otherwise eligible to receive prior to withdrawal.
   3. If the student does not return for the future module after providing written confirmation of future attendance, a return calculation must be completed.
4. Time Frame for Determining a Withdrawal Date for students who withdraw without providing notice
   1. Unofficial withdrawals -The withdrawal date is determined within 30 days of the earlier of: the end of the payment period; end of the academic year; end of the student’s educational program.
5. Rescinding Withdrawal
   1. Aims Community College may allow a student to rescind their official notification to withdraw by filing a written statement that they will continue to participate in academically-related activities and intends to complete the payment period or period of enrollment.
   2. If the student subsequently withdraws after rescinding an intent to withdraw, the withdraw date is the date the student first provided notification to the college or began the college’s withdrawal process, unless a last date of attendance or academically related activity is documented.
6. Extenuating Circumstances Students with extenuating circumstances may not be able to officially withdraw. For these students the college will use the date the college was notified that the student could no longer attend (i.e., death, hospitalization, incarceration, etc.).
7. Academically Related Activity: An academically related activity may be used by faculty to establish the last date of attendance. Academic engagement as defined by regulation: Active participation by a student in an instructional activity related to the student’s course of study that—
   1. Is defined by the institution in accordance with any applicable requirements of its State or accrediting agency;
   2. Includes, but is not limited to—
      1. Attending a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students;
      2. Submitting an academic assignment;
      3. Taking an assessment or an exam;
      4. Participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction;
      5. Participating in a study group, group project, or an online discussion that is assigned by the institution; or
      6. Interacting with an instructor about academic matters; and
   3. Does not include, for example—
      1. Living in institutional housing;
      2. Participating in the institution’s meal plan;
      3. Logging into an online class or tutorial without any further participation; or
      4. Participating in academic counseling or advisement.
8. Calculating Return of Title IV: After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds they were scheduled to receive during the period. If a student withdraws after the 60% point-in-time, there are no unearned funds. A college must still determine whether the student is eligible for a post-withdrawal disbursement.
9. Post-Withdrawal Disbursement: The amount of the post-withdrawal disbursement is the difference between the amount of Title IV funds disbursed and the amount earned.
   1. A college must make a post-withdrawal disbursement of Title IV grant funds within 45 days of the date of determination that the student withdrew.
   2. Refer to most recent FSA Handbook and CFR 668.22 for most up-to-date regulation and requirements for post-withdrawal disbursement
      1. Even though it may be considered in the R2T4 calculation as aid that could have been disbursed, a school cannot make a post-withdrawal disbursement of a:
         1. Second or subsequent Direct Loan disbursement to, or on behalf of, a student who did not graduate or successfully complete the loan period;
         2. Direct Loan disbursement to a first-time, first-year undergraduate who withdrew before completing the first 30 days of her program at a school that is not exempt from the delayed delivery or disbursement requirement;
         3. Direct Loan disbursement to a borrower who has not signed a promissory note; or
         4. Second Direct Loan disbursement to a student who withdrew before successfully completing half the weeks and half the credit or clock hours in the payment period of a nonterm credit-hour program, clock-hour program, or nonstandard-term credit-hour program with terms that are not substantially equal.
      2. You also cannot make a post-withdrawal first disbursement of a Direct Loan to a student enrolled in a program offered in modules who withdrew before beginning attendance in enough classes to establish half-time enrollment.
      3. Post-withdrawal disbursements of any Title IV funds also cannot be made to, or on behalf of, a student for whom the institution did not receive a valid ISIR or SAR by the annual deadline.
10. Post withdrawal notification requirements for Title IV loan funds:
    1. The notification must include the information necessary to make an informed decision on whether the student or parent would like to accept the loan disbursement.
    2. The notice must be sent within 30 calendar days after the date that the college determines the student withdrew.
    3. The notice must permit the parent/student to determine which loan funds, if any, they wish to decline/accept.
    4. The notice must also advise that if there is no response within 14 calendar days or the deadline the school chooses to use, the college is not required to make the post-withdrawal disbursement and funds will be returned to the Title IV loan programs.
    5. If the notification is received from the student/parent within 14 days, the college must disburse loan funds within 180 days. If authorization is received after the 14-day deadline the college must notify the student or parent that the disbursement will not be made and why. However, the school can allow a longer deadline than 14 days for a response and choose to process the post withdrawal disbursement if authorization is given after 14 days or whatever deadline the school chooses to use.
11. Returning Unearned Funds: The college will return Title IV funds to the programs from which the student received aid during the period of enrollment as applicable, in the following order, up to the net amount disbursed from each source:
    1. Unsubsidized Direct Stafford Loans
    2. Subsidized Direct Stafford Loans
    3. Direct PLUS loans received on behalf of a student
    4. Federal Pell Grant
    5. Iraq and Afghanistan Service Grants
    6. Federal Supplemental Educational Opportunity Grants (FSEOG)
    7. TEACH Grants (Aims does not participate in TEACH grants)
12. Deadlines
    1. The college will return unearned funds for which the college is responsible as soon as possible but no later than 45 days after the date of the institution’s determination that the student withdrew
    2. Within 30 days from the date the college determined that the student withdrew, the college will offer a post withdrawal disbursement, if applicable.
    3. If the R2T4 calculation results in a credit balance on the student’s account, it will be disbursed as soon as possible but no later than 14 days after the calculation.
13. Over-award Resolution: Aims Community College considers the returned funds as the student’s debt to the college.
14. Secondary Review of R2T4 Calculations: It is Aims Community College Financial Aid Office Policy to conduct a secondary review on a minimum of 50% of the R2T4 Calculations that are performed each term.
15. Aims Community College Tuition Refund Policy: If a student officially drops a class before the last date to drop the class a refund of 100% of tuition and fees will be made. There will be no refund after that date unless a tuition appeal is submitted and approved by the Tuition Appeals Committee.

The procedures and policies listed above supersede those published previously and are subject to change at any time.