Return of Title IV Funds (R2T4) Policies and Procedures

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Purpose & Scope

It is the policy of the Maine College of Health Professions (MCHP) to follow the federal requirements of 34 CFR 668.22. The federal statute requires MCHP to recalculate federal financial aid eligibility to a Title IV grant or loan recipient who officially or unofficially withdraws or leaves for any reason, including medical withdrawals and administrative or academic dismissals from the college before completing the payment period or period of enrollment. (Modular courses are courses that do not span an entire semester.)

NOTE: MCHP strongly encourages students to read and understand the policies below prior to making a final decision about withdrawing from classes. The requirements for the Title IV program funds when a student withdraws are separate from the Maine College of Health Professions’ refund policy.

Add/Drop Period

If a student’s enrollment changes during the add/drop period, then aid will be re-evaluated based on the new enrollment status, cost of attendance, and award/disbursement procedures for each award type.

  • Pell Grant – will be repackaged if the enrollment status changes before the Pell recalculation date.
  • Direct Loans - If enrollment status remains at least half-time at the end of the add/drop period, the loan funding will not be adjusted even if the enrollment status changes during the add/drop period. The student is still eligible for the amount to be disbursed based on the revised cost of attendance.

If a student drops all courses during the add/drop period and does not begin attending any classes, all aid will be removed before disbursement.

After the add/drop period

If a student attended classes and the last date of activity is recorded in the student information system, then that date is utilized to determine the R2T4 calculation.

Return to Title IV

Federal Financial Aid is disbursed under the assumption that the student will attend for the entire payment period (Semester/Module) for which the student was awarded funds. MCHP will determine how much financial aid the student earned if that student:

  1. Completely withdraws
  2. Stops participating in classes before completing a semester/module or does not complete all modules the student was scheduled to attend.

Institutions are required to determine the amount of Title IV financial aid that was “earned within the payment period.” Software provided by the US Department of Education is used to complete the R2T4 calculation. This calculation must be completed within 30 days of the date the school determines that the student has withdrawn. The school is required to return any unearned funds within 45 days from the date of determination.

Students enrolled in semester courses – The total number of days of the semester, excluding any scheduled breaks of five more days.

Students enrolled in modular courses – The number of days in the modules in which they are enrolled.

Modular Withdraws Reviews for Sessions

If students are enrolled for only one session and withdraw during one session, then the official withdrawal policies and procedures will be used to determine if an R2T4 is needed, and if so, processed using the calendar dates associated with that session.

If students are enrolled for multiple sessions or are enrolled in both a session and a full semester course and are packaged for aid using the entire payment period, then the following questions will be used to determine if the student qualifies as a withdrawn student.

  1. After beginning attendance in the payment period or period of enrollment, did the student cease attendance or fail to begin attendance in a course he or she was scheduled to attend?
    1. When the student ceased attendance or failed to begin attendance in a course he or she was
    2. scheduled to attend, was the student still attending other courses?
  2. When the student ceased attendance or failed to begin attendance in a course he or she was scheduled to attend, was the student still attending other courses?
    1. Yes – This is not a withdrawal. Aid is recalculated based on the add/drop/withdrawal policy.
    2. No- Proceed to number 3
  3. Did a student complete all requirements for graduation at the time of withdrawal?
    1. If Yes – this is not a withdrawal. It may be necessary to recalculate Title IV aid
    2. If No – Proceed to Question 4
  4. Did the student successfully complete Title IV eligible coursework in one module or combination of modules that equals 49% or more of the number of countable days in the payment period?
    1. If Yes – this is not a withdrawal. It may be necessary to recalculate Title IV aid
    2. If No – Proceed to Question 5
  5. Did the student successfully complete Title IV eligible coursework equal to or greater than what the school considers to be half-time enrollment (6 Credits) for the payment period?
    1. a. If Yes – this is not a withdrawal. It may be necessary to recalculate Title IV aid
    2. b. If No – Proceed to question 6
  6. Did the student confirm in writing or via email their intent to attend a course in the module beginning later in the term and no more than 45 days after the withdrawal date from the previous course?
    1. a. If Yes – this is not a withdrawal. Aid is recalculated using the new enrollment type and our policies and procedures for awards received.
    2. If no, complete the R2T4 calculation
    3. If a student provides intent to return to attend a course in the payment period and subsequently wishes to change the re-entry date, he or she may do so by submitting the request in writing.
  7. If a student confirms intent to attend in a module beginning later in the term, but does not actually return, the student is considered to have withdrawn, and the last date of attendance from the most previously attended course is used as the withdrawal date for the R2T4 calculation.
  8. For a student who:
    1. a. Withdraws from a module program;
    2. Does not provide intent to return to a later course
    3. Had aid returned based on an R2T4 calculation;
    4. Re-enters the same program prior to the end of the payment period, the student is considered to have not withdrawn and is eligible to receive Title IV funds for which he or she was eligible prior to withdrawal, including funds returned under the return of Title IV funds provisions and based on the enrollment status upon re-entry.

The order in which Title IV program funds must be returned.

  1. Unsubsidized Direct Loans (Other than Direct PLUS Loans)
  2. Subsidized Direct Loans
  3. Direct PLUS Loans
  4. Federal Pell Grants for which a return of Title IV funds is required
  5. Iraq and Afghanistan Service Grant, for which a return of Title IV funds is required.

Types of Withdrawals

Official Withdrawals

The following procedures are in place at MCHP for official withdrawals:

  1. The student notifies the MCHP Registrar’s Office of intent to withdraw.
    1. MCHP may allow a student to rescind his or her official notification to withdraw by filing a written statement that he or she is continuing to participate in academically related activities and intends to complete the payment period or period of enrollment.
  2. The Registrar notifies the Financial Aid and Student Account Offices of the student’s withdrawal and the official withdrawal date for the R2T4 calculation.
  3. If the student had federal financial aid (Title IV aid), the R2T4 calculation is performed.
    1. The college must determine the amount of Title IV aid a student has earned if he or she withdraws. Within 30 days, the college will calculate the amount of Title IV aid that a student has earned based on the payment period of enrollment. The student will be obligated to pay for any tuition, fees, books, or equipment not covered by Title IV funds.
    2. The amount of assistance that a student has earned is determined on a pro-rata basis. That is, if 25 percent of the payment period has been completed, the student has earned 25 percent of the assistance that he or she was originally scheduled to receive for the payment period. Once a student has completed more than 60 percent of the payment period, he or she will be considered to have earned all Title IV aid.
    3. If a student has received more assistance than he or she has earned, the excess funds must be returned. The funds are returned in the following order: Unsubsidized loan first, Subsidized loan, then Pell Grant last.
    4. If the student has received (or the college received it on his or her behalf) less assistance than the amount earned for the payment period, he or she will be able to receive those additional funds through a post-withdrawal disbursement.
      1. If the student has grant eligibility due to a post-withdrawal disbursement, the school will process grant funds and post them to the student account.
      2. ii. If the student has loan eligibility due to a post-withdrawal, MCHP will offer the loan(s) post-withdrawal and will not process until the student and/or parent has accepted all or a portion of the loan within 30 days of the school sending notification. Once the school has the signed acceptance from the student, MCHP will process the loans and post them to the student's account within the time frames allowed. If the school does not receive notification back from the student, MCHP will not process the loan, and it will not be credited to the student's account. Any unclaimed post-withdrawal loan funds will be returned to the Federal loan program.
  4. If the R2T4 calculation results indicate that the student received more Title IV assistance than they earned, funds are returned to the Education Department using the electronic refund functionality in G5. If the R2T4 calculation results indicate that the student received less Title IV assistance than he or she earned a post-withdrawal disbursement is arranged.
    1. The conditions and limitations for a post-withdrawal disbursement are the same as for all other late disbursements. However, there are additional requirements for late disbursements made as post-withdrawal disbursements. MCHP follows the rules for paying and/or offering a post-withdrawal disbursement in regulations governing the Return of Title IV Funds. From the date MCHP determined that a student withdrew, grants are returned as soon as possible, but not later than 45 days.
    2. Although MCHP must make or offer late disbursement in certain situations, a student is never required to accept it, particularly loans. For example, a student may decline a late disbursement of a loan to avoid taking on additional debt.
    3. The regulations prohibit MCHP from making a late disbursement in certain situations, even if a student otherwise meets the conditions for a late disbursement. MCHP will not make a
      1. Late second or subsequent disbursement of Direct Loan funds unless the student has graduated or successfully completed the loan period;
      2. Late disbursement of Direct Loan funds to a first-year, first-time borrower who withdraws before the 30th day of the student’s program of study (unless the school meets the requirements for a waiver based on low default rates).
      3. Late disbursement later than 180 days after the date the student becomes ineligible.
      4. Late disbursement of a grant later than 45 days after learning of a student’s withdrawal.
  5. The student is notified of the action(s) taken.
    1. Borrowers who withdraw from school will receive exit interview information.

Determining Unofficial Withdrawals

MCHP assumes that the student has unofficially withdrawn if:

  • They began attendance at MCHP and
  • Did not officially withdraw and
  • Failed to earn a passing grade in at least one course during an entire period.

This policy and related procedures are required under the federal Title IV student financial aid programs. MCHP has policies and procedures to identify and timely perform R2T4 calculations for unofficial withdrawals. This requires the collaboration of a number of different areas on campus, including faculty. The policy accounts for:

  1. A student has attended at least one class day.
    1. Prior to performing the R2T4 calculation for an unofficial withdrawal, the college will document that the student attended at least one class day of the course for which the student received a non-passing grade. MCHP cannot assume that the student began attending class simply because the student was registered in the course.
  2. Determining the difference between an earned non-passing grade and an unearned non-passing grade.

The following procedures are in place at MCHP for tracking unofficial withdrawals:

  1. At the end of each semester, the Financial Aid Office (FAO) runs a query of all Title IV aid recipients with all non-passing grades for the enrollment period.
  2. The Registrar’s Office reviews the student’s files. It communicates with faculty as needed to determine if the student had any academic-related activity for the semester and to determine the last day of attendance or the last day of academic-related activity, if available. The list is updated and returned to the FAO for follow-up.
  3. The FAO uses the last date of attendance or last day of academic-related activity, if available, or uses 50 percent of the period date as the withdrawal date, whichever is appropriate.
  4. The FAO performs the R2T4 calculations.
  5. Adjustments are made in the student information system by the FAO.
  6. The students are notified in writing of all returns and any obligations required by the student with instructions.
  7. The Student Accounts staff is notified of any refunds that need to be returned and returns the unearned funds no later than 45 days after MCHP determines the student withdrew.
  8. The Student Accounts office adjusts the student’s account for all Title IV fund reductions.

Procedure

Students wishing to withdraw from the College should contact their Academic Advisor and the Dean and submit a resignation letter to the Registrar. Withdrawal is not considered official until the dated letter of resignation is filed with the Registrar. Until such filing, the student remains enrolled in the College and is responsible for fulfilling its academic and financial requirements.

At MCHP, the following offices are responsible for coordinating the withdrawal process:

  • The Registrar’s Office is the designated contact point for students who choose to withdraw. The student may contact the college in person or via electronic mail.
  • The Financial Aid Office is responsible for performing the R2T4 calculations and to notify the student accounts office of appropriate adjustments to the student’s account.
  • The student accounts staff is responsible for returning any unearned Title IV funds to the Federal Government.

A student’s aid is posted to his or her account at the beginning of each period, and the student earns the funds as they complete the period. If the student withdraws during the payment period, the amount of Title IV earned by the student up to that point is determined by a formula on a pro-rata basis. If the student receives excess program funds that must be returned, MCHP will calculate the portion to be returned to the Federal Government. The portion to be returned will be equal to the lesser of Institutional charges, the unearned % of the funds, or the entire amount of excess funds.

Approved:______________________________________________________________________
Monika Bissell, DBA
President

Date
Revised
3/2017, 3/18/2022, 11/9/2023

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