Return of Federal Financial Aid

Overview

This policy addresses how Federal Student Aid (Title IV) funds are handled when a recipient of those funds ceases to be enrolled prior to the end of a payment period or period of enrollment. The Return of Title IV Funds (which will be referred to as R2T4 Funds throughout the rest of this section) regulations do not dictate an institutional refund policy. Instead, a school is required to determine the earned and unearned portions of Title IV aid as of the date the student ceased attendance based on the amount of time the student spent in attendance. Up through the 60% point in each payment period or period of enrollment, a perorate schedule is used to determine the amount of Title IV funds the student has earned at the time of withdrawal. After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds they were scheduled to receive during the period. Reference: GEN-04-12, GEN-04-03, GEN00-24 and Federal Registrar 11/1/1999, PP. 59016 to 59044

The R2T4 Funds requirement is a complex process involving a great deal of interoffice cooperation and coordination. It should also be noted that the policies and procedures outlined in this section are meant as a guide, but in no way address every detail in regard to the R2T4 Funds process. The policies and procedures outlined in this section along with the guidance provided in the Federal Student Aid Handbook, Chapter 2, Withdrawals and the Return of Title IV Funds, together will address all issues related to the R2T4 Funds process.

It should be noted that for courses offered in modules or mini-terms (includes summer term when students are enrolled in courses that do not span the entire length of the payment period) there is a difference between a withdrawal and a change of enrollment status for R2T4 Fund purposes. The majority of courses offered through Howard University are of the standard term nature, but there are a small number of students who withdraw, for which the new module rules would apply. Unless outlined otherwise in this section, the Federal Student Aid Handbook is the primary source for the steps followed when students withdraw and the courses are determined to be module in nature. Reference: GEN-00-24

In accordance with University policy and Federal regulations governing Title IV financial aid programs, the Office of Financial Aid and Student Employment will determine whether total or partial refund/repayment of financial aid funds may be due when a student withdraws from the University or when there is a change in the student’s financial aid eligibility. This policy does not apply to instances where a student withdraws from some classes but continues to be enrolled at the University.

The date used to calculate the student’s refund or repayment is the effective date reflected on the student’s official University withdrawal form or the drop-out date which is defined as the student’s last recorded day of attendance, as documented by the University. In the case of drop outs (no official withdrawal) it will be based on information reported by the faculty. Students in this category may provide documentation to confirm the last day of class attendance in order to avoid full refund/repayment of financial aid. Below is a list of the financial aid programs to which the R2T4 Funds requirement applies and the order in which funds must be returned by the institution. Reference: 668.22(a)(2) and GEN-06-05

Refunds

Unsubsidized Federal Stafford loans
Subsidized Federal Stafford loans
Unsubsidized Federal Direct Stafford Loans
Subsidized Federal Direct Stafford Loans
Federal Perkins loans
Federal Parent Loans for Undergraduate Students (PLUS)
Federal Direct PLUS loans
Federal Pell Grants
Federal Supplemental Educational Opportunity Grant Program Awards
Other Federal Title IV assistance programs
Other Federal, State, private, or institutional assistance programs
The student

Repayment

It should be noted that the Federal Perkins Loan program has been removed from the list above, the program was discontinued.

To make sure we are clear on terminology, below are definitions of some relevant terms that will be referenced throughout this section.

A refund: is defined in relationship to money paid towards University charges. The refund is the amount paid by financial aid or in cash minus any amount that is kept covering charges for the period of enrollment. The amount that the University retains will be determined in keeping with federal guidelines which require that the University apply either prorated refund calculations as applicable to first-time Howard University enrollees, or the University refund policy applicable to all others, in order to ensure return of the greater refund to the student financial aid programs.

The term “repayment”: relates to any cash disbursed directly to the student for payment of non-institutional educational costs such as living expenses. The repayment is the amount of cash disbursements determined to be greater than the student’s expenses while they were enrolled and therefore must be returned.

Title IV Grant or Loan Recipient: A student who actually received Title IV funds or has met the conditions that entitle the student to a late disbursement. Reference 668.22(I)(4) and 668.164(g)(2)

Institutional Charges: Charges that were initially assessed the student for the entire payment period or period of enrollment as applicable. Institutional charges are generally defined as the charges for tuition and fees, room and board and other educational expenses that are paid to the school directly. Reference 668.22(g)(1)(ii) and 668.22(g)(2)

Title IV Disbursement: When Title IV funds, previously listed above, are credited to a student’s University account (can also include funds that could have been disbursed). Reference 668.164(a)

Title IV Leave of Absence (LOA): Is a temporary interruption in a student’s program of study. At Howard University “students who find it necessary to withdraw from all of their classes for the current semester or for a subsequent semester for which they have already registered”, therefore, students are considered to have withdrawn and a R2T4 Funds calculation would need to be performed. Reference 668.22(d), 668.22(d)(1), GEN-04-12 and GEN-04-03

Withdrawal: Total Class Withdrawals: Students who find it necessary to withdraw from all of their classes for the current semester or for a subsequent semester for which they have already registered.

Unofficial Withdrawals: students who never attend or stop attending without officially withdrawing.

Students are made aware of Howard University Withdrawal Policy and procedures (steps students must follow) via University website “Add, Drops & Withdrawal“ as well as the Student Handbook.

Steps for Completing a Total Withdrawal

Students who find it necessary to withdraw from all of their classes for the current semester or for a subsequent semester for which they have already registered must complete a Total Withdrawal Request Form. This form must be submitted by the end of the 12th week of classes for the semester in which they wish to withdraw. The withdrawal form and instructions are available from the dean or Office of Undergraduate Studies of each school or college. Students who are physically unable to complete the withdrawal in person, students who are administratively withdrawn, and students who have special needs due to extenuating circumstances should contact the Office of Student Services.

Students considering a total withdrawal should note the following:

The effective date of the withdrawal will be the date on which the student submits the form to the Office of the Registrar.
- Financial aid staff receive a report biweekly that lists all students who have withdrawn either officially or unofficially (faculty initiated). It lists the effective date of withdrawal.
- This document is used to determine when a R2TIV calculation is required.

By registering for courses, students accept financial responsibility for payment for those courses and for any other charges incurred while they are enrolled.
Financial aid may be adjusted or canceled as a result of withdrawal and may require repayment of loan funds. Adjustments to financial aid awards will be calculated according to University and Federal refund guidelines based on the official withdrawal date.
Once the withdrawal has been completed, students will receive a grade of “Wm” for each course.
Students who reside in University housing are required to check out of their residence hall within 24 hours of completing the total withdrawal process.
Completing a total withdrawal from the University requires that students surrender all University property, including, but not limited to library books, room keys, computer cards, and identification/access cards.
Students who complete a total withdrawal from the University must apply for or request readmission to the University by published deadlines. The procedure for readmission depends on the length of the student’s absence from the University.

Withdrawal Date

Howard University faculty are not required to take attendance by the university or any outside source such as the U.S. Department of Education, state authority, accrediting agency, etc. Therefore, the withdrawal date for official/unofficial withdrawals as noted below and in most cases be based upon other information available to individuals in the various colleges who are making this determination. Reference: 668.22(b),(c) and 668.22(b)(3)

For module programs, if a student ceases attendance at any point prior to completing the payment period or period of enrollment, unless the school obtains written confirmation from the students at the time of withdrawal that he/she will attend a module that begins later in the same payment period, the student is considered a withdrawal. Reference: GEN-00-24

Regardless of the type of withdrawal, the OFA has 30 days from the point they are notified or the end of the term to determine the status of the students in question. Additionally, they have 45 days from the point they are notified or from the end of the term to return the appropriate funds to the U.S. Department of Education.

ABSENCE FROM THE UNIVERSITY: Failure to attend classes, abandonment of a residence hall space to which one has been assigned, or not returning for classes for an upcoming semester (for which one is already academically and financially registered) does not constitute official discontinuance or withdrawal. Students who find it necessary to withdraw from all their classes for the current semester, or for a subsequent semester for which they have already registered, must complete a Total Withdrawal Request Form. (Need a copy of Total Withdrawal Form)

TOTAL WITHDRAWAL POLICY: As aforementioned, students who find it necessary to withdraw from all their classes for the current semester, or for a subsequent semester, for which they have already registered, must complete an online Total Withdrawal Request Form. This form must be submitted by the end of the 12th week of classes for the semester in which they wish to withdraw. The withdrawal form and instructions are available from the Office of the Dean or Advisory Center of each school or college. Students who are physically unable to complete the withdrawal in person and students who are administratively withdrawn should contact their Dean or advisor for assistance. Students considering a total withdrawal should note the following:

The effective date of the withdrawal will be the date on which the Office of the Registrar receives the completed withdrawal request form.

THE UNOFFICIAL WITHDRAWAL POLICY: Assists the University in administering its Title IV federal financial aid program. Department of Education regulations require the return of disbursed federal financial aid received by students who do not attend and participate in courses for which they are not enrolled. The University must adjust the federal financial aid of all students who either never report or stop attending and participating within the first 60 percent of the semester.

In previous years, "UW" and "NR" grades reported as final grades did not affect a student's grade point average. But henceforth, students who never attend or stop attending without officially withdrawing will adversely affect their grade point averages through the failing grades they will earn at the end of the semester.

Students who find it necessary to drop/withdraw from a course must complete the official process by the required deadline. Please refer to the University Calendar for specific dates and deadlines.

WITHDRAWAL POLICY/LEAVE OF ABSENCE: Students should complete the online withdrawal form. Students are highly encouraged to discuss the reasons for and the implications of the withdrawal. For students who decide to continue with the withdrawal process the electronic form will be routed as follows to the offices that correspond with their student status:

Veterans, students with disabilities, and students who have judicial stipulations should report to the Office of Special Student Services, , Oddfellows Building, 9th and T Street NW.
International students must report to the Office of International Student Services, Rm. G-10, Administration Building
Students who reside in University housing must report to the Office of Residence Life, College Hall South
Students who received any type of financial aid (including scholarships, grants, and loans) must report to the Office of Financial Aid, Rm. 205 Administration Building to discuss the effect of withdrawal on their award(s) and potential financial aid over payment
All students must report to the Office of the Bursar. Rm. 218, Administration Building to discuss the status of and adjustments to their account.
All students must report to Office of the Registrar, Rm. 104 Administration Building to submit the completed Total Withdrawal Request form and surrender their Bison One Card.
RETROACTIVE WITHDRAW PROCESS: Unique circumstances arise for which a retroactive withdrawal is appropriate. In such cases the process will be imitated by the Office of the Dean for the schools. The effective date will be determined by the Office of the Registrar, but the date for the R2TIV calculation timeline will be the date the withdrawal is entered in Banner. (See SFASTCA)

Formula Calculation

Based upon a student’s receipt of Title IV funds and them not completing the term for which they received funds, an R2T4 Funds calculation may need to be processed. As previously outlined, the actual determination will differ slightly based upon how the student withdrew and/or notification from faculty or designated support staff. In most cases, the “last date of attendance” will be based upon the withdrawal date as recorded by the Registrar’s Office. For unofficial withdrawals, the determination will be based upon the dates faculty reported students to have last taken part in an academically-related activity as reported when they submit grades. Any conflicting information is resolved by reviewing archived documentation in OnBase and/or financial aid office emails to faculty. In such cases that a student has completed less than 60% or we are unable to determine LDA, regulations indicate that institutions can default to the midpoint in the term.
The OFA is responsible for calculating the R2TIV. They use FAA Access system for the calculation.
The use of payment period versus period of enrollment may differ based upon if the student was enrolled in module programs and/or enrolled at Howard with multiple start and end dates. As previously mentioned the majority of the programs offered at Howard are of the standard term nature, however due to the flexibility allowed students in registration, period of enrollment must also be used. Reference: 668.22(e)(5)
Students are assessed institutional charges by the Registrar one term (payment period) at a time. Thus there is no need to prorate institutional charges as students are not charged for multiple terms. At the time of withdrawal, the institutional charges as posted in Banner on TSIQACT are used in the calculation. The most common examples are tuition, fees and room and board. Non-institutional charges or other institutional charges such as parking fines, late fees, visits to campus health clinics for treatment, etc. are not included. Reference: 668.22(g)(3)
In the process of completing the R2T4 Funds calculation, it may be determined that the student is due a post-withdrawal disbursement. This could include all types of Title IV aid funds. Post-withdrawal. Reference: 668.22(I)(1) and 668.164(g)(3)

Post-withdrawal Disbursements

As per the R2T4 Funds calculation as detailed in the previous section, if the student receives less Federal Student Aid than the amount earned, the school must offer a disbursement of the earned aid that was not received. This is called a post-withdrawal disbursement. In determining a post-withdrawal disbursement, staff must keep in mind other required conditions of a late disbursement as outlined in the Federal Student Handbook. Reference: 668.22(a)(4),(5) and GEN-04-12 and GEN-04-13

Upon determining that a student (or parent) is eligible for a post-withdrawal disbursement, we must first determine the sources from which it will be funded and credit any grant portion towards allowable and/or authorized unpaid charges. If institutional charges have been paid in full, any additional post-withdrawal disbursement of grant funds can be directly disbursed to the student. If the student (or parent) is eligible for additional loan funds we must offer and obtain the student’s or (parent’s in the case of a parent PLUS), authorization to credit the loan portion of the post-withdrawal disbursement towards allowable and/or unpaid charges. Just like with excess grant funds, the student (or parent PLUS borrower) needs to be offered any portion of the post-withdrawal disbursement of loan funds in excess of the institutional charges. An emailed letter will be sent to the appropriate individual requesting that they respond within a certain timeframe if they are interested in receiving the post-withdrawal disbursement. Reference: 668.22(a)(5)(ii)(A)(1), 668.22(a)(5)(ii)(A)(2), 668.22(a)(5)(iii)
(B)(1) and 668.22(a)(5)(ii)(B)(2)

Returning Unearned Funds

Via the R2T4 Fund calculation the amount of unearned aid is determined by subtracting earned aid from disbursed aid. Once determined, the next step is to determine the responsibility for returning unearned aid between the school and the student. Unearned funds must be returned to the appropriate Title IV programs in the order outlined below. Reference: 668.22(g)-(i)

Federal Unsubsidized Direct Stafford Loan
Federal Subsidized Direct Stafford Loan
Federal Direct PLUS Loan
Federal Pell Grant
Federal SEOG
Federal TEACH Grant
Iraq and Afghanistan Service Grant

Overpayment Resolution

As previously mentioned, in all cases the institution will return the funds on behalf of the student who owes an overpayment and consider the returned funds as the student’s debt to the institution. As with any debt to the institution the student can work out a payment plan or other payment arrangements to pay the university what they owe with the Office of the Bursar. Reference: GEN-06-05 and GEN-05-17

As a result of how the funds are repaid to the federal government, the student would not owe an overpayment with the U.S. Department of Education, thus future eligibility for Title IV aid would not be affected. However, it should be noted that when students have outstanding bills with the university and have not made satisfactory payment arrangements, it can result in a hold being placed on the students account and restricting future registration, the release of transcripts, etc.