Navigating R2T4 MASFAA November 16, 2006 Allene Begley Curto, Springfield College Thomas Threlkeld, US ED
Navigation Tools for Return of Federal Aid • When we are requiredto return federal aid • When we are requiredto offer federal aid not yet disbursed • How a student earns federal aid based on attendance • How we know when a student has begun or has withdrawn (officially or unofficially) • What has changed with HERA
The Basic Concepts behind the Requirements… • If you never began attending, you are not eligible for federal aid • If you began but did not complete the term, you may not be eligible for all of the aid that you received • If you began but did not complete the term, you may still be eligible for some of the aid that you did not yet receive • US ED requires the school to know if a student began attendance and whether they completed the term
We are requiredto return federal aid… • If a student began attendance, but withdrew before completing 60% of the term • If a student failed to pass any course in a term and the school can not document that the student completed at least 60% of the term
We are required to offera post-withdrawal disbursement.... • If a student began attendance, did not complete the term, but has earned aid which has not yet been disbursed, and • The student meets the requirements for a late disbursement
What Aid has been earned? • Did they begin? • Did they complete? • If they began but didn’t complete, what percent of the term did they complete? • What do we know and when did we know it?
Who Knows? Who Tells FAO? • How does the school know if a student began attendance in at least one course? • How does the school know if the student stopped attending? • Who reviews students who fail to pass at least one course in a term? • How is FAO notified on any and all of the above? • How is it documented by the school?
Percentage Completed Days Attended divided by Days in the Term = Percentage completed Exclude scheduled breaks that are at least 5 consecutive days from both Days Attended and Days in the Term
Nonterm Credit HoursClock Hours • Nonterm Credit Hour programs – Number of Credit hours expected to be completed in payment period divided by number of credit hours completed at withdrawal. • Clock Hours – Total number of clock hours scheduled to be completed at time of withdrawal divided by total clock hours in period
HERA CHANGES • Effective for withdrawals that occurred on or after July 1, 2006 • Scheduled Clock Hours • Leaves of Absence • Grant Overpayments • Programs from which Funds are Returned • Return of Funds Timeline • Post-Withdrawal Disbursement Counseling
HERA Changes -Clock Hours • Only scheduled hours are used, no longer any formula to determine whether it should be scheduled or completed • A student earns 100% of his or her aid if the student’s withdrawal date is after the point that he or she was scheduled to completed at least 60% of the scheduled hours in the payment period or period of enrollment
HERA Changes –Leaves of Absence • US ED clarifies that an institution may grant more than one leave of absence to a student Other LOA rules remain • No more than 180 days total in any 12 month period • Must follow school’s written policy • School may not asses any additional charges • …and all other LOA requirements
HERA Changes –Grant Overpayment • Limited to the amount by which the original grant overpayment is greater than half of the total Title IV grant funds received by student • A student does not have to repay a grant overpayment of $50 or less • No changes to the grant repayments required to be made by the school
HERA Changes – Programs from which Funds are Returned • Pell Grant, SEOG, FFEL, Federal Direct Loan, Federal Perkins Loan, ACG, SMART • No longer applies to LEAP, SLEAP, GEAR UP and SSS • No change to the exclusion of FWS
HERA Changes –Post-Withdrawal Disbursement Counseling • School required to contact student prior to making a post-withdrawal disbursement of loan funds • Explain obligation to repay loan funds • Confirm loan funds still required by student • Document result of contact in file • Applies even if student owes balance to school
HERA Changes – Return of Funds Timeline • Must return unearned funds within 45 days of the date that it determines that student ahs withdrawn (previously 30 days) • Note that date that school determines student has withdrawn is not the date that FAO became aware of the fact! • Note that return is required in 45 days, not just the calculation!
Why we should know if a student began/completed the term… • Successful completion of the educational program is the goal • Enrollment retention requires knowledge of who is really here • Students need response/support/action if not attending or don’t register