KASFAA Spring Conference Erlanger KY April 12, 2012

Withdrawing from Term-Based Programs with Modules/Compressed Courses OLD RULE

Return of Title IV Funds & Programs Offered In Modules

1

Michael C. Roberts Title IV Training Officer Federal Student Aid

If enrolled in mini-terms within a term and student completes at least one course, student is NOT considered to be withdrawn for Title IV purposes (no R2T4).

2

Programs with Modules – New Rule

Program Definition

 Student considered to be withdrawn if: – For credit hours, did not complete all the days in the payment period or period of enrollment student was scheduled to complete

• New rules define a program that is – “offered in modules” A course (or courses) in a program that does not span entire length of payment period or period of enrollment

• EVEN IF COMPLETED A COURSE

• Does not matter what “modules” are called at the institution • Effective July 1, 2011 3

GEN-11-14 provides a series of Q & As and examples in reference to the new R2T4 regs 4

Programs with Modules – New Rule

Programs with Modules – New Rule

 For a payment period or period of enrollment where courses are offered in modules –

 If obtained written confirmation for future attendance:

– A student is NOT considered to have withdrawn if the school obtains written confirmation (can be electronic) from student at the time that would have been a withdrawal that the student will attend a later module in same PP/PE • If nonterm or nonstandard, next module must start within 45 calendar days after the end of module the student ceased attending (unless on approved LOA) 5

– Student may change date of return to a later module in the same PP or PE as long as – • Provided in writing prior to the original return date  If nonterm or nonstandard, the later module cannot begin later than 45 days after end of the module ceased attending

– If a student does not receive a passing grade in the course(s) in the last module, school must demonstrate student completed module 6

For Discussion Purposes Only

1

R2T4 Calendar Days Modular Programs

Programs with Modules - New Rule  If student does not return as scheduled –

• Total calendar days include all days on which the student was scheduled to attend

– Considered withdrawn – Withdrawal date and total number of calendar days are those that would have applied if written confirmation was not provided

– Days of completed courses count if course does not span length of term – Include days between modules if least than 5 consecutive days – Exclude scheduled breaks of at least 5 consecutive days when student not scheduled to attend a module or other course offered during that period

• Courses officially dropped prior to ceasing attendance are NOT days the student is scheduled to attend unless still enrolled in other courses on those days • Total number of days in a PP or PE in which courses are offered in modules

• For a withdrawn student who has made schedule changes

 Do NOT include scheduled breaks of at least 5 days when the student is not scheduled to attend a module or course during that period 8

7

When a Student is Considered a Withdrawal

Is Student A Withdrawal? New Rule 1. Did the student cease to attend before completing or fail to begin attendance in a course scheduled to attend?  If yes, go to question 2.  If no, student not a withdrawal 2. When ceased to attend or failed to begin attendance in a scheduled course, was the student attending other courses?  If yes, student not a withdrawal  If no, go to question 3 3. Did the student confirm attendance in a later module in the payment/enrollment period (45 day rule, if applicable)?  If no, student is a withdrawal.  If not a withdrawal, Pell recalculations may apply Please note – If not a withdrawal, Pell recalculation may apply.

9

– Do not count days of courses officially dropped prior to complete cessation of attendance

• In a program measured in credit hours – Student does not complete all the days scheduled to complete in the PP or POE • In a program measured in clock hours – Student does not complete all the clock hours and weeks of instructional time scheduled to complete in the PP or POE

10

Required to Take Attendance?

When a Student is Considered a Withdrawal

• If an institution is required to take attendance, the withdrawal date is always the last date of academic attendance; §668.22 (b)(1). • For an institution that is not required to take attendance, the withdrawal date is determined in accordance with the requirements of §668.22 (c).

• In a non-term or non-standard term – Student is not scheduled to begin another course within a PP or POE for more than 45 calendar days after the end of the module the student ceased attending • Unless the student is on an approved LOA

11

12

For Discussion Purposes Only

2

Written confirmation

Written confirmation (cont’d)

• For courses offered in modules

13

– A student is not considered to have withdrawn if, • For standard term programs, the institution obtains written confirmation that the student will return to complete a later module within the same PP or POE • For non-term and non-standard terms – the institution obtains written confirmation that module begins no later than 45 calendar days after the end of the module the student ceased attendance • Must be obtained prior to requirements to complete R2T4 (i.e., 45 days)

• Student can revise the date of return to a later module, if – Student does so in writing, between the time of the withdrawal, but prior to the return date – For non-term and non-standard term programs, the later module begins no later than 45 calendar days after the end of the module the student ceased attendance

14

“Offered in Modules” - Institution A

“Offered in Modules” – Institution A

• Institution A: – Fall and Spring = standard terms • Never considered to be “offered in modules” – Summer = three 5-week sessions (combined to be a standard term)

• Student #1 – Enrolls in all three summer sessions and ceases enrollment on Day 5 in the first 5-week session

• Students can enroll in any of the summer sessions or all of them • Students enrolled in the 5-week summer sessions are considered in programs “offered in modules” since none of the sessions span the entire length of the term (the 15week period)

15

16

“Offered in Modules” – Institution A

Session 1 5 weeks 35 days

Session 2 5 weeks 35 days

“Offered in Modules” – Institution A

Session 3 5 weeks

• Student #2: Enrolls in all three summer sessions

35 days

On Withdrawal Day 5 student also drops remaining sessions. Institution Required to Take Attendance – WD = Day 5. Denominator = 105 days. Per GEN 04-12, the institution must have a process to make this determination no later than 14 days after the LDA. Note: If institution not Required to Take Attendance – WD = midpoint of PP/POE – Day 52. Denominator = 105 days.

– Day 5 of session 1, drops session 2 – Day 8 of session 1, withdraws during the first 5wk session – Student does not provide written confirmation of return within the payment period – Institution required to take attendance

For Discussion Purposes Only

3

“Offered in Modules” – Institution A

“Offered in Modules” – Institution A

• The Results: • The Results:

– Step 1 – Recalculate Pell (690.80(b)(2)(ii)) – Step 2 – Determine earned & unearned amounts of Title IV aid (TIV) • Numerator = # of days attended in Course 1 (assume no breaks) 5 days • Denominator = Start date of Course 1 thru end date of Course 3 (less any scheduled break of 5 or more consecutive days or approved LOAs) 105 days or .048 or 4.8%

– Step 1 – Recalculate Pell – 690.80(b)(2)(ii) – Step 2 – Determine earned & unearned amounts of TIV • Numerator = number of days attended (assume no breaks) 8 days • Denominator = 35 days each in sessions 1 & 3, less any scheduled breaks or approved LOAs 70 days or .114 or 11.4% Note: If institution Not required to take attendance – WD = midpoint of PP/POE – Day 35. Denominator = 70 days.

“Written Confirmation” Institution B

“Written Confirmation” – Institution B

Session 1 5 weeks

• Student #3 – Enrolls in all three summer sessions Drops session 2 on day 4 Ceases enrollment on Day 5 in the first 5-week session but provides written confirmation of future return

35 days

Session 2 5 weeks 35 days

Session 3 5 weeks 35 days

Day 4 – drops Session 2 Day 5 – withdraws from Session 1 and provides written confirmation that student will return to Session 3.

21

“Written Confirmation” – Institution B

Written Confirmation – Institution B • What happens when the student doesn’t return for module 3?

• The Results:

• The withdrawal date (WD) is • At an institution required to take attendance = the last date of attendance (LDA) • At an institution not required to take attendance = midpoint or the last date of an academicallyrelated activity

– Step 1 – Recalculation of Pell • When the student indicates s/he will not be returning to take all the modules the Pell award was based upon

– Step 2 – No R2T4 calculation due to the fact that the student provides written confirmation of her/his planned return between the time of the withdrawal and before the start of the third module

24

For Discussion Purposes Only

4

Administrative Withdrawals

“Written Confirmation” – Institution B

• If institution cancels a module class after the end of the prior module, R2T4 is required.

• The Results:

– Include the total days in both modules (denominator) – Withdrawal date and date of determination

– Step 3 – Day 71 – Student does not return. WD = Day 4 at Institution Required to Take Attendance; – Midpoint (1/2 [35 + 35] = Day 35) or Academically-related activity at an Institution not Required to Take Attendance.

• Required to take attendance – WD is last date of attendance of prior module and DOD is date of cancelation • Not required to take attendance – WD and DOD is date of cancellation

• If cancellation occurs during a prior module, 26

Withdrawn Student Returns (“undo” R2T4)

– Pell recalculation required – R2T4 not required

Withdrawn Student Returns (“undo” R2T4) conti.

• Modular term-based credit hour program – Withdrawn student may return to same program prior to end of payment period/period of enrollment • Student eligible for any Title IV funds for which eligible prior to withdrawal including funds that were returned by the institution or student (with no adjustment required for partial attendance of a prior module) • However, Pell recalculations required if did not start all classes (did not attend an entire prior 27 module)

• Clock hour/nonterm credit hour program – Withdrawn student may return to same program within 180 calendar days • Student eligible for any Title IV funds for which eligible prior to withdrawal

28

Resources/References • • • •

FSA Handbook, Vol. 5, Chapter 2 34 CFR 668.22 Dear Colleague Letters - GEN-04-03; GEN-11-14 FSA Assessments

Questions Michael C. Roberts 404-974-9313 [email protected]

– http://www.ifap.ed.gov/qahome/fsaassessment.html

• R2T4 website through FAA Access to CPS Online • R2T4 Demo Site available at

Feedback on Training Thomas Threlkeld Supervisor of Training Officers 617-289-0144; [email protected]

– http://fafsademo.test.ed.gov

• 10/29/10 Federal Register • Final – Program Integrity 29

30

For Discussion Purposes Only

5