If a student ceases attendance in the first of three modules he or she is scheduled to attend in a payment period or period of enrollment and subsequently drops the classes in the two remaining modules prior to the beginning of module two, does the total number of calendar days in the payment period or period of enrollment include all the days in all the modules, or just the first module?
What if the student drops the classes in the two remaining modules prior to ceasing attendance in the first module?
MOD-Q When performing an R2T4 calculation, are the days between modules included in the total number of calendar days in the period? MOD-A The total number of calendar days in the payment period or period of enrollment includes all days in the payment period or period of enrollment, excluding days in which the student was on an approved leave of absence, and scheduled breaks of at least five consecutive days when the student is not scheduled to attend a module or other course offered during that period of time.
So, breaks between modules that the student is scheduled to attend of at least five consecutive days are excluded from the total number of calendar days in the period when calculating the percentage of the period completed by the student.
Please note this only applies to the process for determining the denominator for the R2T4 calculation. This is not the process for determining whether a student successfully completed at least 49 percent of the payment period for purposes of determining whether the student qualifies for an exemption from the R2T4 requirements see question WI-Q4 below. MOD-Q Section MOD-A The midpoint of the payment period or period of enrollment would be the 50 percent point of the total number of calendar days in the payment period or period of enrollment.
Consider a student who, after completing the first module and does not qualify for a withdrawal exemption , withdraws on day 20 of the second module of a period comprising two eight-week modules with a four-day break in between. Therefore, the midpoint and, thus, the withdrawal date would be day Note that there may be situations where the withdrawal date determined using this method occurs slightly before or after the 50 percent point in the term.
For example, the midpoint of a term that includes calendar days would be the 59th day of the term because the institution, using normal rounding rules, would round the result of the calculation In such cases, an institution must always treat the student as having earned exactly 50 percent of their Title IV funds for the period even if the calculation based on the withdrawal date at the midpoint would otherwise result in a different percentage for example, 59 divided by equals Does this mean that an institution must delay the first disbursement of Direct Loan funds until the student has begun attendance in enough hours to qualify as a half-time student?
MOD-A No, an institution is not required to delay the first disbursement of a Direct Loan until the student has begun attendance in enough classes to qualify as a half-time student. Title IV, HEA program funds are disbursed to a student on the presumption that he or she will attend the hours for which aid has been awarded. Therefore, an institution is not required to delay the disbursement of Title IV, HEA program funds until a student has attended enough hours to qualify for the enrollment status for which the funds were awarded.
However, if the student has withdrawn and has not begun attendance in enough courses to establish a half-time enrollment status, the presumption is no longer valid. Thus, the institution may not make a first disbursement of a Direct Loan i.
Take, for example, a credit hour program where each semester comprises three modules of five weeks each. However, if the student withdraws during the first module and the institution has not made the first disbursement of a Direct Loan to the student prior to the withdrawal, the institution may not make that first disbursement of the Direct Loan to the student at this point. MOD-Q The preamble to the final regulations effective July 1, states, "If the student has not begun attendance in enough courses to establish a half-time enrollment status, the institution may not make a first disbursement of a Direct Loan to a student 34 CFR Why is an institution prohibited from making a second disbursement of Pell Grant funds?
An institution would not be prohibited from making a second disbursement of Pell Grant funds if the R2T4 calculation resulted in a post-withdrawal disbursement of Pell Grant funds. We published a correction to the preamble language in the Federal Register on April 13, 76 FR MOD-Q If a student who is scheduled to attend all three modules in a payment period or period of enrollment drops the classes in the two remaining modules in the period between the first and second module when the student is not attending any classes , are the days in modules two and three included in the total number of calendar days in the payment period or period of enrollment?
MOD-Q If a student or an institution drops classes on the same day that the student withdraws, is the student's enrollment status adjusted to reflect the dropped classes for R2T4 purposes? If a student withdraws from all other courses in the payment period or period of enrollment, as applicable, except for the non-Title IV eligible course s they are completing or repeating, are they a withdrawal for Title IV purposes?
How does this apply to programs offered in modules? MOD-A If a student withdraws from all Title IV eligible courses in the payment period or period of enrollment, and continues to attend only the course s that he or she is completing or repeating for which he or she may not receive Title IV aid during that period, the student is a withdrawal for Title IV purposes. This is because a student is considered to be attending a Title IV eligible program only if they are attending one or more courses in that program for which the student is receiving Title IV, HEA program funds.
Therefore, a student who ceased attendance in all of the Title IV eligible courses is considered to be no longer attending a Title IV eligible program and is a withdrawal for Title IV purposes, regardless of any continued attendance in courses for which the student may not receive Title IV, HEA program funds during that period.
For example, a student enrolls in four courses in the spring semester, three for the first time and one for the third time, having received Title IV aid and earning a grade of "D" for the repeated course the two previous times. If the student then ceases attendance in the three courses he is taking for the first time, the student is a withdrawal for Title IV purposes, even though the student remains enrolled in the course he is repeating, because he ceased attendance in the Title IV eligible part of the program scheduled for that period.
Likewise, if a student who received an incomplete in a course in the prior term is completing the coursework in the subsequent term to erase the incomplete from the prior term, the student is not eligible for Title IV, HEA program funds for completion of the coursework.
If the student withdraws from all the Title IV eligible coursework in which he or she is enrolled, but remains in attendance in only the coursework that needs to be completed from the previous term, the student is a withdrawal for Title IV purposes. The principle is the same for programs offered in modules. For example, a student is scheduled to attend one course in each of five modules during a semester.
The student receives an incomplete in course number two in the second module and, because the student may not progress to course number three until course number two is completed, the student completes the remaining portion of course number two in the third module.
While the student completes the incomplete portion of course number two in the third module, he or she is not be considered to be enrolled in the course for Title IV purposes, so attendance of just that course does not count as attendance for purposes of the R2T4 requirements. Absent written confirmation of future attendance or being placed on an approved leave of absence, a Return to Title IV Funds calculation would be required absent withdrawal exemptions or the student completing more than 60 percent of the period before withdrawing.
MOD-Q If a student who withdrew from a non-term credit hour program failed hours in the payment period, must the payment period be extended by the number of days necessary for successful completion of those hours? MOD-A The total number of calendar days in the period must reflect the actual days the student would have had to attend to successfully complete all the hours the student was originally scheduled to complete in the period.
Dear Colleague Letter GEN November provides that, for non-term credit hour programs, if the student has not successfully completed any courses in the payment period, the payment period must be extended to reflect the number of days in the failed courses that the student did not successfully complete.
Completion of a payment period occurs when a student successfully completes the hours and weeks of instructional time in the period. If a student has not passed all the coursework associated with the hours in the payment period in addition to completing the weeks of instructional time, unless the graduation withdrawal exemption applies , the student has not completed the payment period. If more than one course must be added for successful completion of the hours in the payment period and those courses could have been taken concurrently by the student had he or she remained enrolled, then the payment period would be extended by the days necessary to take the courses concurrently.
However, if the only way the student could have taken the courses was consecutively, then the added days must reflect the days it would have taken to complete the courses consecutively. MOD-Q A student met the conditions for a withdrawal exemption through successful completion of coursework, but later ceased attendance in other coursework during the payment period or period of enrollment. At the time that the student ceased attendance, the institution had not disbursed all of the Pell Grant and Direct Loan funds for which the student was otherwise eligible.
In this situation, is the institution permitted to disburse any remaining amounts of Pell or Direct Loan funds? MOD-A When a student meets the conditions for a withdrawal exemption, the student is treated as having completed the payment period and, for purposes of the Title IV programs, is considered enrolled through the end of the period even if the student later stops attending future coursework or modules in that period.
Additionally, the institution must disburse any remaining Pell Grant funds for which the student is eligible before the end of the payment period. If the institution fails to disburse all of the Pell Grant funds for which the student is eligible until after the payment period is over, a subsequent disbursement of Pell Grant funds for the period is treated as a retroactive or late disbursement that is subject to all requirements for such disbursements, including the requirement under 34 CFR For Direct Loan purposes, when a student ceases attendance during a payment period after meeting the conditions for a withdrawal exemption, the institution must disburse Direct Loan funds for which a student is eligible during the payment period only if the student is enrolled at least half time at the time of disbursement.
If the student ceased attendance prior to attending coursework that comprised at least half-time enrollment, it is impossible for that student to enroll half-time during the period unless the student resumes attendance later in the period. Therefore, in this situation the institution cannot make the Direct Loan disbursement unless it confirms that the student commenced attendance in coursework that comprises at least half-time attendance during the payment period.
If the institution fails to make the disbursement of Direct Loan funds until after the payment period is over, the disbursement is treated as a retroactive or late disbursement that is subject to all requirements for such disbursements. As an example, consider a student who enrolls in two eight-week modules within a payment period. The student is awarded Pell Grant and Direct Loans, but due to administrative delays the institution is unable to make the Title IV disbursements while the student is still in attendance.
The student successfully completes the first module and meets the conditions for a withdrawal exemption. The student then begins the second module, but ceases attendance prior to receiving any Title IV disbursements for the period.
The student is considered a completer and, for Title IV purposes, remains enrolled throughout the entire payment period. The student qualifies for a Pell Grant disbursement at half-time enrollment status because the student was enrolled half-time on the Pell recalculation date and the student began attendance in coursework sufficient to comprise half-time enrollment. For Direct Loan purposes, the student was enrolled half-time and had begun attendance in coursework that comprised half-time enrollment at the time the student ceased attendance.
Therefore, the institution must disburse the Direct Loan funds for which the student is eligible during the payment period. This scenario would change significantly if, after completing the first module, the student never began attendance in the second module. In that case, since the student never began attendance in coursework sufficient for half-time enrollment, the student would be subject to a mandatory Pell Grant recalculation and would only qualify for a less-than-half-time Pell Grant disbursement.
In this circumstance, the student would also be ineligible to receive Direct Loan funds for the period because the student never commenced attendance in coursework comprising half-time enrollment.
MOD-Q Our institution has three summer periods in which students can enroll in coursework and those sessions are combined into a single summer term for the purposes of awarding Title IV funds.
Is our summer term considered to be offered in modules? MOD-A Yes. If an institution combines multiple summer sessions into a single term for Title IV purposes, and none of those sessions span the entire term, each of the summer sessions is considered a module and a student enrolling in any one of those session is treated as being enrolled in a program offered in modules for that term.
Does this day rule for determining a withdrawal apply to all institutions that fall under the definition of an institution that is required to take attendance i.
How does the day rule apply when a student is not treated as a withdrawal from a program offered in modules because he or she has confirmed attendance in a module that begins later in the payment period or period of enrollment? TA-A1: The day rule applies to all institutions that are required to take attendance. Institutions that are required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdraws.
For example, a student enrolls at an institution that is required to take attendance for one course in each of three modules. The student completes the first module, but ceases attending the second module on October 4, prior to its completion. The student provides written confirmation that he will attend the third module, scheduled to begin October 24, but does not return. In accordance with the previous guidance, if a student provides notification to the institution of his or her withdrawal prior to the date that the institution normally would determine that the student withdrew, the date of determination is the date of the student's notification.
The institution is NOT required to administratively withdraw a student who has been absent for 14 days. However, after 14 days, it is expected to have determined whether the student intends to return to classes or to withdraw. If the student is eventually determined to be a withdrawal, the end of the day period begins the timeframe for completing a R2T4 calculation. If an institution has a policy that states the maximum number of excused absences that can occur after which a student will be administratively withdrawn, it may delay contacting the student until that date.
An institution must return the amount of Title IV funds for which it is responsible as soon as possible, but no later than 45 days after it determines or should have determined that the student withdrew. TA-Q2: If an institution monitors whether its online students log into classes, is this an institution that is required to take attendance? TA-A2: No. The monitoring of whether online students log into classes does not by itself result in an institution being an institution that is required to take attendance for Title IV, HEA program purposes because monitoring logins alone is not monitoring academic engagement as defined under 34 CFR TA-A3: Yes.
Take, for example, a student who is not in attendance in his or her classes on the last day of a two-week period of required attendance taking. TA-A4: No. Only if the institution requires its faculty to collect or record information about whether a student was in attendance is it considered to be one that is required to take attendance.
TA-Q5: If an institution requires its faculty to take attendance for some courses in a program, but not others for example, all core courses, but not elective courses , is this an institution that is required to take attendance? TA-A5: An institution is only required to take attendance if attendance taking is required in all classes in the program for a period of time.
If, for example, an institution requires that attendance be taken in all core courses, but not elective courses, and the core and elective courses are always taken together throughout a payment period, then the institution would not be classified as being required to take attendance for that program because attendance taking is not required for all courses for any period of time.
However, if the core courses in the program are taken together in isolation—for example, over the first five weeks of a payment period—then this would be a program for which the institution is required to take attendance for those first five weeks because, for that period of time, attendance is required in all courses. TA-Q6: Please confirm that an institution is not an institution that is required to take attendance if it has a census that reviews which students academically attended during a defined preceding period--e.
TA-A6: Section So, if the institution is taking attendance on just the 14th day, it is not an institution that is required to take attendance for Title IV, HEA program purposes. Also, if the institution is taking attendance to determine whether each student attended at least once during the period, but is not continuing to monitor attendance for a student subsequent to the one day of attendance, it is not an institution that is required to take attendance for Title IV, HEA program purposes.
TA-Q7: For a program that is offered in modules, may the institution require that attendance be taken on only one specified day for each module i. TA-Q8: If faculty at an institution are required to take attendance and some faculty do not comply with the requirement, how should the institution determine a withdrawal date for a student who withdraws?
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