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Return to Title IV Policy

Return to Title IV Funds 

Title IV funds (Federal Student Aid) are awarded under the assumption that students will attend school for the entire semester for which the funds are awarded. 34 CFR 668.22 requires schools to apply the Return of Title IV calculation to the record of any federal student aid recipient who does not complete their period of enrollment/semester.

Official Withdrawal 

An official withdrawal occurs when a student (recipient of Title IV grant or loan funds) drops or withdraws classes (or is administratively dropped/withdrawn by a school). 34 CFR 668.22 (b) (c)

Unofficial Withdrawal

If a student fails to earn a passing grade in at least one course, he or she enrolled in for a semester, the Student Financial Aid office must assume for FSA purposes that the student has unofficially withdrawn, unless it can be documented that the student did complete the term. For example, a student receives all “F” and/or “D (dropped)” and/or “W” grades for a term. 34 CFR 668.22 (b) (c

Financial aid Office is required to determine if the student “unofficially withdrew” from classes. An “unofficial withdrawal” occurs when a student stops attending all classes and stops participating in any academic activities beyond the date he/she last attended classes. The determination date the college may use will be any one of the following dates that best represents the last of documentable date of attendance:

· Date provided by an instructor (Last known Activity Attendance)

· Withdrawal (or dropped) date (use of LKAA or W, whichever is the latest)

· Mid-point of the payment period when none of the above data is available


Generally, for a student who withdraws after the 60% point of the payment period, there are no unearned funds. However, if all eligible funds or a percentage of the eligible funds is yet to be fully disbursed at the time of the calculation, the student will receive a Post Withdrawal Disbursement notification letter within 30 days from the determination date.  

The notification will provide information on the award eligibility, the amount the student is eligible to receive, the deadline to respond, and the instructions on accepting the disbursement (acceptance is required within 14 days of the notification for Direct Loans only). The funds will be disbursed no later than 45 days from the determination date.

Students who completely withdraw from all classes they are currently attending but remain enrolled in classes that begin later in the term (future or late start classes) must provide a written statement confirming they intend to return to complete their future start classes. Without the statement, institutions are required to perform the R2T4 calculation based on the date the student withdrew from the classes in which they began attendance.  

If a student is required to repay any unearned portion of the award disbursed (directly to the student or used to pay the school), the student will receive an email notification detailing the amount owed and the name of the program.  

For a student that withdraws from all classes on or before the 60% point of the term, a portion of unearned funds may be required to the returned by the college, the student and/or both. 34 C.F.R §668.22 (a)(5),34 C.F.R. §668.22(g) and (j), 34 C.F.R. §668.164(h)

The students are exempt and not considered withdrawn if:

· A student who completes all the requirements for graduation from his or her program before completing the days or hours in the period that he or she was scheduled to complete is not considered to have withdrawn.

· In a program offered in modules, a student is not considered to have withdrawn if the student successfully complete one of the following:

1. A combination of successfully completed classes in modules (mini modules) that when combined contain 49 percent or more of the number of days in the payment period, excluding scheduled breaks of five or more consecutive days and all days between modules; or

2. Successfully completed classes in modules equal to or greater than the coursework required for the institution's definition of a half-time student under Sec. 668.2 for the payment period at the time of the withdrawal.

3. A student is not considered to have withdrawn if the institution obtains written confirmation from the student at the time that would have been a withdrawal of the date he or she will attend a module that begins later in the same payment period (future enrollment) and for standard and nonstandard-term programs, that module (mini module) begins no later than 45 calendar days after the end of the module the student ceased attending;

a. During the first 60% of the semester of enrollment, a student earns aid in direct proportion to the length of time of his/her enrollment.

b. Any portion of the aid disbursed for which the school is responsible to repay to the U.S. Department of Education’s aid program(s) will be returned as soon as possible but no later than 45 days from the determination date of the withdrawal. 34 C.F.R. §668.22(g) and (j)

c. If a student is required to repay any unearned portion of disbursed Federal funds (disbursed directly to the student or used to pay educational expenses in the reporting school for the Aid year), the student will receive an email notification detailing the amount owed and the name of the program. The student will have 45 calendar days from the date on the notification to repay the funds directly to the school. On the 45th day (end of business day), the overpayment will be reported to the US Department of Education for collection. The student will be eligible for additional Title IV funds once the repayment is resolved, or a repayment agreement is signed between the student and the financial aid office (the eligibility will be recovered if the student honors the repayment agreement). 34 C.F.R. §668.22(h)

i. Once the balance owed is transferred from the college to the U.S. Department of Education, the student can contact the Department of Education by calling 1-800-621-3115.

· Any disbursed unearned federal student aid as determined by the R2T4 calculation will be returned by the college and/or the student in accordance with the method prescribed in regulations 34 C.F.R. §668.22(i). The amount will be returned in the following priority order:

o Federal Unsubsidized Direct Loan

o Federal Subsidized Direct Loan

o Federal Direct PLUS Loan (if required)

o Federal Pell Grant (if required)

o Federal Supplemental Opportunity Grant (FSEOG, if required)

o Iraq and Afghanistan Service Grant

· Student repayment exceptions:

o Any Direct Loan funds will be repaid according to the terms and conditions of the Master Promissory Note.

o Any wages paid to a student from the Federal Work Study program are wages earned and do not need to be repaid.


For the scheduled 60% point of the payment period, please refer to the college webpage. 34 C.F.R. §668.22(e) and (f).

Any student planning to withdraw from classes or drop out of school should contact the Financial Aid Office and consider discussing the decision with an academic counselor. There are programs and/or services to assist students in staying on track with their educational goals