Return of Title IV Funds Policy

This policy--known as the Return of Title IV Funds (R2T4) Policy--applies to anyone who receives financial aid, certifies their enrollment in registered classes, and then subsequently withdraws or fails to earn a grade during the term. This includes scenarios involving suspension or expulsion. It is highly recommended that any student contemplating dropping a class for which they registered contact the CC Financial Aid office to setup an appointment to discuss altering their scheduled enrollment and what impact that may have on their financial aid funding.

Important Definition

Withdraw(n)(al): When a student does not maintain attendance/enrollment in all the calendar days during the payment period (semester) for which they were awarded financial aid and the student does not provide a written statement to the CC Dean of Students Office before the day they ceased attendance/dropped the class certifying they planned to attend a course during a future block in the same payment period (semester). Certification of future block enrollment will not be accepted as true and accurate information if the submitting student is in fact not registered for a future block in the semester at the time their certification statement is reviewed. Such students will be considered a withdrawn student for financial aid purposes. If a student cannot register for a future block in the same semester because one does not exist, the student is considered withdrawn for federal purposes. There are few federal exemptions to this policy:

• 1. A student is not considered to have withdrawn if the student successfully completes one module that includes 49% or more of the number of days in the payment period, excluding scheduled breaks of five or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.
  2. A student is not considered to have withdrawn if the student successfully completes a combination of modules that cumulatively contain 49% or more of the number of days in the payment period, excluding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.
  3. A student is not considered to have withdrawn if the student successfully completes course work equal to or greater than the course work required for the institution’s definition of a half-time student under 34CFR668.2(b) for the payment period.

It is important to note that a student can either be considered an official withdraw or an unofficial withdraw. "Withdraw" is a federally-recognized term with an explicit federal definition and specific governing regulations.

R2T4 Policy Overview

Title IV (Federal) funds are awarded to CC students under the assumption that they will attend classes for the entire payment period (semester) for which the assistance is awarded. If a student withdraws from the College, for any reason including medical issues, the student may no longer be eligible for the full amount of financial aid funding they were originally scheduled to receive.

If a student withdraws from the College prior to attending at least 60% of the total calendar days that comprise their initially-scheduled enrollment period, the student may be required to return or repay a portion of the financial aid they received for that term. The FSA programs that are covered by this federal requirement are: Federal Pell Grants, Federal Direct Stafford Loans, Federal Direct PLUS Loans, Federal Supplemental Educational Opportunity Grants (FSEOG), and other Title IV Programs. A pro rata schedule is used to determine the amount of federal student aid funds a withdrawn student has earned at the time of their withdrawal. Institutional and state aid is prorated based on any resulting reduction to the student's COA for that term (i.e. 1/3 or 2/3 reduction). If a student withdraws during the 100% refund (add/drop) period during block 1 or block 5, all their financial aid for that term will be cancelled and returned.

Withdrawal Process

Any student wishing to withdraw from Colorado College has the responsibility of initiating the withdrawal process. The official withdrawal procedure is completed through the CC Advising Hub. If a student is contemplating not attending class at CC for one or more blocks, before a semester begins or during, it is highly recommended that they setup an appointment to speak with a CC Financial Aid staff member about what effect their time away from the classroom, however brief, may have on their financial aid funding.

Official Withdrawal Process

To officially withdraw from Colorado College, a student must submit a withdrawal application to the Dean of Students office. The completed application will then be circulated to all pertinent offices by the Dean's office, however, it is highly recommended that students who choose to withdraw from the College visit the CC Financial Aid Office as well as the CC Student Accounts Office to ensure they understand what will happen with their financial aid and their bill. If a withdrawing student does not intend to re-enroll in CC classes in the future, the College requires they complete an exit interview with the Dean of Students Office.

If a student is unable to complete the official withdrawal process, an intent to withdraw must be communicated to the Dean of Student's Office in writing (email or letter).

Unofficial Withdrawal

At Colorado College there are three potential instances of unofficial withdrawal for a student.

(1) If a student ceases attending a scheduled class without completing the official withdrawal process, they will have the grade of WF recorded for that course. Students assigned a grade of WF, Y, or switch to auditing (Z) after the block in review has begun and that do not begin attendance in the next block in the same payment period (semester) as confirmed by their professor will be considered unofficially withdrawn for the semester.

(2) If a student does not attend classes for 60 calendar days and has not filed a Block Off request or a Withdrawal with Intent to Return request they will be dropped from the College and treated as an unofficial withdrawal.

(3) If a student does not successfully complete (with a passing grade) any of courses they were scheduled to attend in a given term and does not officially withdraw or otherwise provide notice of their intent to withdraw, they will be considered "unofficially withdrawn".

In all three cases, federal regulations mandate a federal Title IV fund return calculation be preformed.

Determining the Withdrawal Date

A student's withdrawal date is determined by one of the following, by Colorado College:

• The date the student began the official withdrawal process
• The date the student otherwise notified a designated office of his or her intent to withdraw
• The date that the school determines is related to circumstances beyond the student's control
• The date the student ceased attendance without providing official notification
• The mid-point of the semester

For an official withdrawal, the effective withdrawal date is the first day a student notifies the Dean's Office or other designated official offices of their intent to withdrawal.

For an unofficial withdrawal due to the student not completing a class or classes, the effective withdrawal date could be the midpoint of the term or last date of documented academically-related activity, whichever the CC Financial Aid Office determines best reflects the student's term enrollment.

For an unofficial withdrawal due to a student being academically dismissed, the effective withdrawal date is the date of their notification of dismissal is sent. For suspended students, the withdrawal date is the due date for the suspension appeal if the appeal is denied.

We may use a last date of attendance for the effective withdrawal date if there is an emergency situation and there is third party documentation that verifies when a student stopped attending class.

CC does not simply accept a student's self-reported last date of attendance to complete its R2T4 responsibilities.

Regulations require schools to perform calculations within 30 days from the date the school determines a student has withdrawn. CC must return funds within 45 days of the calculation.

Please note: if you have work-study, the withdrawal date is also the last day you may work in your work-study position.

Returning after Withdrawing

Student who are granted an approved Institutional Leave status by the CC Dean of Students and do not attend a college elsewhere during their leave, generally are able to have their financial aid eligibility renewed upon their return to CC.

Federal Title IV Refund Calculation Policy

The Colorado College Financial Aid Office determines, based on the federally mandated formula, the amount of FSA/Title IV assistance a withdrawn student has earned, based on their determined withdrawal date. The Return of Title IV Funding (R2T4) calculation policy is outlined below:

Step 1: Student's Title IV Information

Our office will determine:

• The total amount of Title IV aid disbursed (if any) for the term from which a student withdrew.
• The total amount of aid that could have disbursed (if any) for the term from which a student withdrew.

Step 2: Percentage of Title IV Aid Earned

We will calculate the percentage of aid earned as follows:

The number of calendar days completed by the student divided by the total number of calendar days in their initially scheduled enrollment period.

Days Attended / Days in Enrollment Period = Percentage Completed

If a student's calculated percentage exceeds 60%, then that student has "earned" all aid for the period. An R2T4 calculation must be completed for a that withdrawn student but they will not be required to repay or return any federal funding. Institutional and state aid may still be adjusted down.

Step 3: Amount of Title IV Aid Earned

We will calculate the amount of aid earned as follows:

The percentage of Title IV aid earned (step 2) multiplied by the total amount of Title IV aid disbursed or that could have disbursed for the term in which the student withdrew (Step 1).

Total Aid Disbursed x Percentage of Title IV Aid Earned = Amount of Aid Earned

Step 4: Amount of Title IV Aid to be Returned, Repaid, or Post-Withdrawal Disbursed

• If the aid already disbursed to a withdrawn student equals the amount of earned aid, no further action is required.
• If the aid already disbursed is greater than the amount of earned aid, the difference must be returned to the appropriate Title IV aid program.

Total Disbursed Aid for Semester - Amount of Earned Aid = Unearned Aid to be Returned or Repaid

• If the aid already disbursed is less than the earned aid, and a student has aid for that term that could have disbursed[1], we will calculate a post-withdrawal disbursement (PWD). If this post-withdrawal disbursement contains loan funds, you may elect to decline these funds so you do not incur additional debt. You will be notified of any additional disbursements via email to your CC account. Students have fourteen days to respond to a Post-Withdrawal Loan Disbursement notification otherwise the CC Financial Aid office will assume those students do not want those monies and their PWD will be cancelled. A PWD of grant funds must be disbursed within 45 days of the date of the school’s determination that the student has withdrawn. A PWD of loan funds must be offered to the student within 30 days of the date of the school’s determination that the student has withdrawn, allowing the student at least 14 days to respond to accept or decline funds. 

Step 5: Amount of Unearned Title IV Aid Due from the School

Colorado College must return the lesser of:

• the amount of Title IV funds that the student does not earn
• the amount of institutional charges that the student incurred for the payment period of enrollment multiplied by the percentage of funds that was not earned.

Step 6: Return of Title IV Funds by the School

Colorado College mmust return Title IV funds to the programs from which the student receive aid during the payment period as applicable, in the following order, up to the net amount disbursed from each source:

        1. Unsubsidized Federal Direct Loans (other than Direct Plus Loans)
        2. Subsidized Federal Direct loans
        3. Direct PLUS loans (parent or graduate)
        4. Pell Grant
        5. Iraq and Afghanistan Service Grant
        6. SEOG

Step 7: Initial Amount of Unearned Title IV Aid Due from the Student

Title IV regulations specify that a student is responsible for all unearned Title IV aid that Colorado College is not required to return.  This responsibility is determined by subtracting the amount returned by Colorado College from the total amount of unearned Title IV funds to be returned. However, Colorado College chooses to return all necessary grant monies to the Department of Education directly (including the student's portion) and then bills students appropriately for the resulting balance owed to the College.

Step 8: Repayment of Student Loans

The student loans that remain outstanding to be returned to the Department of Education due to the R2T4 process being triggered by a withdrawal, consist of the loans disbursed to the student minus any loans the school repaid in Step 6. These outstanding loans are repaid by the student according to the terms of the student’s promissory note(s).

Step 9: Title IV Grant Funds to be Returned by a Student

The amount of grant overpayment due from a student is limited to the amount by which the original grant overpayment (step 7) exceeds half of the total Title IV grant funds disbursed and could have been disbursed to the student. However, Colorado College chooses to return all necessary grant monies to the Department of Education directly (including the student's portion) and then bills students appropriately for the resulting balance owed to the College.

Step 10: Return of Title IV Grant Funds by the Student

The student's portion of Title IV grant funding due back to the Department of Education must be returned in the same order that is required for schools (Colorado College).

R2T4 Consequences

• Any funds returned by the College, including loan funds, may result in a balance due and owing to the CC Student Accounts office immediately.
• For withdrawan students only receiving Title IV monies (i.e. any aid listed in step 6) and expecting an unrealized credit refund, such refunds will be processed as soon as possible and no later than 14 days after your R2T4 calculation is complete.
• A student's grace period for loan repayment of federal Direct Student Loans and federal Perkins Loans will begin on the day it is determined they withdrew from the College. Students should contact their loan servicer directly if they have questions regarding their loans' grace period or repayment status.
  
  

[1] Federal regulations define what it means for a student to have "Title IV funding that could have disbursed" as well as what constitutes their "institutional charges".

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