Return to Title IV Funds Policy

R2T4 (Return to Title IV)

General Policy and Procedures

Calvin is not required to take attendance. Therefore, the following dates and definitions are used in determining applicable steps in returning any Title IV (TIV) funds as well as institutional funds. It is imperative any communication from the Registrar’s Office identify the category(ies) and date(s) identified below pertaining to each student’s situation. Calvin offers a limited number of online/distance education courses. Online courses are treated in the same manner as on-campus courses for both billing and financial aid purposes.

1. Official Withdrawals – When a student decides to discontinue from a given payment period at Calvin, s/he must notify the Registrar’s Office. Receiving notification from the student confirms the withdrawal is official. The Registrar’s Office immediately notifies multiple offices (Financial Aid, Financial Services, Housing, and Student Life/Judicial Affairs and others as needed) by way of email of any official discontinuation.
   
   
   1. Withdrawal Date: An official withdrawal will always have a student withdrawal date. This is the date the student begins the withdrawal process OR the date the student otherwise provides notification of intent to withdrawal. (Verbal communication of intent to an academic counselor in their counseling role is considered notification, an informal discussion in a dorm lobby with the RA or RD is not.) If both circumstances occur, Calvin will most likely use the earlier date. However, if a student communicates intent to withdraw or begins the withdraw process but continues to attend a course(s) or participate in any academic activity Calvin will use the last date of an academic related activity as the student’s withdrawal date. If a student is registered for courses at any status level during a semester and subsequently withdrawals, the student enrollment status will be reported timely as withdrawn to NSLDS to ensure appropriate treatment of a student’s federal loans (repayment, grace period, deferment), regardless of the completion of any courses within the given term.
      
      
   2. Determination Date: This is the date Calvin determined the withdrawal date for a student. This date begins the 45-day period for any return of TIV funds.
      
      
   3. Refund Date: This is the required date(s) for any refund of funds, whether TIV or institutional. TIV refunds are calculated by a distinct formula and governed by a 45-day return period from the Determination Date. Refunds of Calvin charges and institutional aid will be determined by the Financial Aid Office (with the Financial Services Office if needed), and absent an exception for special circumstances will be pro-rated in accordance with the Calvin’s refund policy.
      
      
   4. Incident Date: If applicable, this is a Judicial Affairs term and may have impact on determining items A and B above. This date may be the same as either A and/or B but does not automatically become a student’s withdrawal date.
      
      
   5. Procedures for Official Withdrawals:
      1. The Registrar’s Office creates and distributes a daily Discontinuation Report. This report includes any student who has withdrawn from Calvin in the preceding 24 hours. This report is distributed to multiple offices (Housing, Financial Services etc.) each using it as needed for their own purposes.
      2. Students on the report are evaluated to determine if s/he is receiving any TIV aid for the given term. If yes, the FAO follows federal requirements for calculating and returning federal funds as needed. This calculation will be determined using assessed charges to the student, not budgeted or expected charges. This calculation is based on the dates as identified above for each particular student. Calvin calculates and submits R2T4 calculations for all students receiving TIV aid at any point in the payment period, even after the student has earned 100% of aid and no refund is required. If required to return federal funds they are returned in this order:
         1. Unsubsidized direct loans (other than Direct PLUS loans)
         2. Subsidized direct loans
         3. Federal Perkins Loans
         4. Direct PLUS loans
         5. Pell Grant
         6. FSEOG
         7. TEACH
         8. IASG
      3. Institutional refunds are calculated based on Calvin’s institutional policy.
      4. State of Michigan refunds are calculated according to state policy. Current state policy is linked to Calvin’s census date (day 10) for a given term. A student’s enrollment status on day 10 determines their state award for that term. Completely withdrawing at a later date does not require a state recalculation. An enrollment adjustment changing a student’s day 10 enrollment would require a re-evaluation for a state award.
      5. If the amount of a student’s award(s) has changed b/c of any of the above calculations the new amount of the award for the given term is entered on AIDE. Supporting comments should be entered in the applicable comments section.
      6. If a student who borrowed through the federal direct loan program withdrawals or adjusts enrollment such that their remaining enrolment is less than half time the rule governing greater than half-time enrollment within colleague must be deleted. Failure to do this will cause the loan to automatically get denied, which may or may not be correct.
      7. R2T4 calculation sheets and other applicable institutional calculations are kept in a file for the given term and available as needed.
      8. While rare, a withdrawn student may not have received the full amount of federal funds they have earned. In this case a student would be due a post-withdrawal disbursement.
         1. If a post-withdrawal disbursement includes loan funds, the college must get the student’s permission before it can disburse the funds. A student may choose to decline some or all of the loan funds so as not to incur additional debt.
         2. The college may automatically use all or a portion of a post-withdrawal disbursement of grant funds for tuition, fees, and room and board charges.
         3. The college needs the student’s permission to use the post-withdrawal grant disbursement for all other college charges.
         4. If a student does not provide permission, the student will still be offered the funds. However, it may be in the student’s best interest to allow the college to keep the funds to reduce the student’s debt at the college.
            
            
   6. Unique Scenarios within a Calvin academic calendar: Calvin has a standard, two-term academic year. Each term is considered a payment period and there are two payment periods for each academic year. It is possible a given student may enroll in a class or classes that do not run the full length of the term. Should this occur the student is considered to be enrolled in a program consisting of modules for that given term. This is a student by student evaluation as well as term by term evaluation.
      
      When a student withdraws from a standard term-based program comprised of a series of modules, the college determines whether an R2T4 calculation is required and if so, the length of the payment period or period of enrollment. Among the variables to consider are whether the student has completed at least one course and if not, whether the student intends to return for another module within the term and has provided official written notification of intent to return.
      
      Currently interim and spring semester at Calvin are the most common modules. They are combined and considered a standard term-based program beginning the first day of interim and concluding with the last day of exams for the spring semester. This was determined since the courses and modules have the following characteristic: students enroll up front for courses in all of the modules they plan to attend for the entire term. However, some students may subsequently add or drop a course in a later module.
      
      
   7. Determining if a student enrolled in modules for a given term has withdrawn. (Example scenarios listed at the end this document)
      1. Under the October 29, 2010, final regulations, for all programs offered in modules, a student is considered to have withdrawn for Title IV purposes if the student ceases attendance at any point prior to completing the payment period or period of enrollment, unless the school obtains written confirmation from the student at the time of the withdrawal that he or she will attend a module that begins later in the same payment period or period of enrollment.
      2. If a school obtains a written confirmation of future attendance but the student does not return as scheduled, the student is considered to have withdrawn from the payment period or period of enrollment.
      3. Calvin uses a series or questions to evaluate is a student is considered to have withdrawn or not:
         1. Question 1: After beginning attendance in the payment period or period of enrollment did the student stop attending or fail to begin attendance in a course he or she was scheduled to attend? If the answer is no, this is not a withdrawal. If the answer is yes, go to question 2.
         2. Question 2: When the student ceased to attend or failed to begin attendance in a course he or she was scheduled to attend, was the student still attending any other courses? If the answer is yes, this is not a withdrawal; however, other regulatory provisions concerning enrollment recalculation may apply. If the answer is no, go to question 3.
         3. Question 3: Did the student confirm attendance in a course in a module beginning later in the period (for non-term and nonstandard-term programs, this must be no later than 45 calendar days after the end of the module the student ceased attending)? If the answer is yes, this is not a withdrawal, unless the student does not return. If the answer is no, this is a withdrawal and the return of Title IV Funds requirements apply.
      4. This series of questions and the supporting logic is applied to any term at Calvin when it’s determined a student is enrolled in modules.
         1. Summer classes at Calvin are a series of three modules for which the same questions can be applied.
         2. It’s possible a student in the fall term may be considered enrolled in modules if one or more of their classes does not span the entire length of the payment period of period of enrollment. A student withdrawing during the fall term would be evaluated based on the same three questions.
            
            
   8. Calendar Days in a Module Program:
      1. Total calendar days include all days in which the student was scheduled to attend:
         1. Days of completed courses count if course does not span length of term
         2. Exclude scheduled breaks of at least 5 consecutive days when student not scheduled to attend a module or other course offered during that period
      2. For a withdrawn student who has made schedule changes
         1. Exclude days of courses officially dropped prior to complete cessation of attendance
            
            
   9. Day 10 Awarding Adjustments for Interim/Spring Semester:
      1. Institutional aid – only use spring semester enrollment to calculate institutional aid
      2. Federal Aid, campus based, and State of Michigan – use both spring and interim enrollment for federal calculation
      3. COA – full-time tuition + spring semester charge = new COA
      4. Awards will be reviewed prior to sending the first bill for the interim/spring term for those students enrolled for 11 hours or fewer. After the spring census day students are evaluated again and any needed adjustments are made based on any changes to enrollment status since the last evaluation of enrollment.
         
         
2. Unofficial Withdrawals – Students who simply cease attending all classes in a given payment period and give no notification of non-attendance are considered unofficial withdrawals for that payment period. Identification of students in this category during the payment period is quite challenging.
   
   
   1. Unofficial Withdrawal Report: At the conclusion of the payment period the Registrar’s Office provides the FAO with a list of students who have at least one grade of either F, I or N. The FAO evaluates this list to determine if any students could be considered unofficial withdrawals.
      1. FAO must determine a student’s unofficial withdrawal date within 30 calendar days of the end of the payment period, the end of the academic year, or the end of the student’s educational program, whatever is earlier. Typically, this is the end of the payment period.
      2. A student with a grade of F, I or N who has any other passing grade (D- or better) for the payment period in question is deemed to have completed that class and therefore the student cannot be considered a completely withdrawn student.
      3. A student with only grades of F, I or N is potentially an unofficial withdraw and will require further investigation.
         
         1. The FAO will contact the student’s professors to determine if the student was ever in class for the term. If yes, every attempt will be made to determine the student’s date of last attendance. This can be the last day a student was physically present in class as indicated by the professor, participation in a study group, turning in assignments etc.
         2. If the professor confirms the student began the class but has no documentation regarding when the student ceased attendance and there are no circumstances beyond the student’s control (hospitalization, illness etc.) the student’s last date of attendance will be the midpoint of the payment period.
         3. The date of determination is the date Calvin became aware the student ceased attendance. Typically, this is after the payment period has concluded.
         4. If no confirmation can be obtained from anyone involved that the student ever started the term (i.e. never came to one class, never participated in any academic activity) the student will be deemed to have never been enrolled whatsoever. In this case the FAO will take the appropriate steps to return any TIV funds as well as institutional funds.

Example Withdrawal Scenarios

1. Student begins mod 1 and withdraws from mod 2 while still enrolled in mod 1. Not a withdrawal but may have to check for Pell recalculation based on new enrollment info for mod 1. (Reference is FSA Handbook June 2017 Scenario 3 on page 5-65)

2. Student begins mod 1, completes mod 1 and withdraws from mod 2 during the break between mod 1 and mod 2. No written confirmation of attendance in a later module rec’d. Student is a withdrawal and R2T4 calcs need to be submitted. For calculation purposes, all the days of mod 2 are included in R2T4 calculations. (Reference is FSA Handbook June 2017 Scenario 3 on page 5-68)

3. Student begins mod 1, completes mod 1 and never begins (no attendance in any class, no academic related activity etc) mod 2 b/c the classes were deleted, and the student is treated as if he never enrolled for the spring term. Official discontinuation rec’d from Registrar’s Office and confirmation is rec’d from faculty members that student never was in attendance at all. Because the classes were “deleted” by the Registrar’s Office the answer to question 1 of the three-question series becomes “no”. By completing mod 1, and b/c the rest of the classes have been deleted, there are no other classes that the student was “scheduled to attend”. (Reference is FSA Handbook June 2017 p 5-64)