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Return of Federal Title IV Financial Aid Policy

Return of Federal Title IV Financial Aid

A federal financial aid (Title IV) recipient who withdraws from the College is subject to a Return of Title IV (R2T4) calculation. For the purpose of R2T4 calculation requirements, a recipient is a student who has actually received federal financial aid funds or has met the conditions that entitled the student to a late disbursement of federal financial aid funds. The College is required to review the amount of federal loan and grant aid a student received for the payment period, to determine what percentage of federal financial aid the student earned prior to withdrawal. The percentage of federal financial aid determined to be unearned for the payment period must be returned to the appropriate federal financial aid program(s).


When a federal financial aid recipient withdraws from the College prior to the end of a payment period (degree programs), or the period of enrollment (diploma programs), an R2T4 calculation must be performed to determine the amount of federal financial aid funds earned as of the date of withdrawal. If the total amount of federal financial aid funds earned is less than the amount of federal financial aid funds disbursed to the student or on behalf of the student in the case of a parent PLUS Loan, the difference between these amounts is returned to the applicable federal financial aid programs. If federal financial aid funds earned is greater than federal financial aid funds disbursed, the difference between these amounts is treated as a post withdrawal disbursement. An R2T4 calculation is not performed if the federal financial aid recipient withdraws after successfully completing the entire payment period and all funds awarded for that period have been disbursed.

Return Calculation

The amount of federal financial aid earned is calculated by determining the percentage of aid earned and applying this percentage to the total amount of aid disbursed and that could have been disbursed for the payment period or period of enrollment. The payment period for degree students is the individual term.  The period of enrollment for Vocational Nursing is the academic year.  The period of enrollment for all other diploma programs is the entire program length. For purposes of determining earned federal financial aid, a student’s aid is considered disbursed if it is disbursed as of the student’s last documented date of attendance. As long as conditions for a late disbursement (described below) are met prior to the date the student became ineligible (the student’s last date of attendance), any undisbursed federal financial aid will be counted as aid that could have been disbursed. 

Conditions for a Late Disbursement (Including PostWithdrawal Disbursements)

  • The Department of Education (ED) processed a Student Aid Report (SAR) or Institutional Student
  • Information Record (ISIR) with an official Expected Family Contribution (EFC) for the student (except in the case of a parent PLUS Loan)
  • The College originated a Direct Loan (DL)
  • The College made the award to the student for a Federal Supplemental Educational Opportunity Grant (FSEOG)

The College does not include as a post-withdrawal disbursement any funds the College was prohibited from disbursing on or before the date the student withdrew, which would apply to the following:

  • Second or subsequent disbursements of DL funds unless the student has graduated or successfully completed the loan period.
  • Second disbursements of DL for the period that the College is prohibited from making until the student successfully completes one-half of the weeks of instructional time and one half the credit hours in the academic year.
  • Disbursements of Federal Pell Grant and Iraq Afghanistan Service Grant funds to a student for whom the College did not receive a valid SAR or a valid ISIR by the deadline date established by the Department of Education
  • Federal Pell Grant and Iraq Afghanistan Service Grant funds for a subsequent payment period when the student has not successfully completed the earlier payment period for which the student has already been paid.

Inadvertent Overpayments

An inadvertent overpayment occurs when the College disburses funds to a student no longer in attendance but prior to the date the College determines the student withdrew from the program.  This would include any federal financial aid fund disbursements made after the student’s last date of attendance but prior to the College’s determination that the student was withdrawn.  These inadvertent overpayments are included in the R2T4 calculation as aid that could have been disbursed.  Only students who meet late disbursement criteria are entitled to keep federal financial aid funds disbursed as an inadvertent overpayment.  If an inadvertent overpayment cannot be made as a late disbursement, the College returns the entire amount of the federal financial aid funds disbursed. If the inadvertent overpayment can be made as a late disbursement, the College returns only the unearned portion of the inadvertent overpayment within 45 days of the College’s date of determination that the student withdrew.  Unearned inadvertent overpayments are returned according to the requirements for the return of unearned funds.

Verification and the Return Calculation

If a student provides required verification documents after withdrawing from the College, but within 30 days of the date of the notification informing the student of the requirements, and in time for the College to meet the 30-day Return deadline, the College performs the R2T4 calculation based on all federal financial aid the student had established eligibility for prior to the withdrawal.  For the Federal Pell Grant Program, if the student provides the verification documents after the 30-day deadline but before the earlier of 120 days after the student’s last date of attendance or the deadline established by ED each award year, the College reviews and addresses eligibility as required.  If a student does not provide all verification documents in time for the College to complete verification and meet the R2T4 deadlines, the College includes in the R2T4 calculation only the federal financial aid that was not subject to verification (unsubsidized and PLUS Loan funds) and for which the conditions of a late disbursement were met prior to the withdrawal.

Institutionally Scheduled Breaks

Institutionally scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation for degree programs and all diploma programs except Vocational Nursing and Dental Assisting. For Vocational Nursing and Dental Assisting, progress toward completion is based on scheduled hours rather than calendar days.

When Funds Are Disbursed Using Different Payment Periods

When the College disburses different types of aid using different payment periods, e.g., one payment period for disbursing grant funds and another payment period for disbursing DL, only one payment period is used in determining earned funds. The payment period ending later is used for the R2T4 calculation.

Percentage of Federal Financial Aid Earned

The calculation of Percentage of Federal Financial Aid Earned includes all financial aid disbursed or that could have been disbursed to a student. This percentage is equal to the percentage of the payment period or period of enrollment completed by the student as of the student’s last date of attendance in the payment period or period of enrollment. If the student withdraws after successfully completing the payment period or period of enrollment, 100% of the federal financial aid funds are earned and no calculation is required. If the withdraw date occurs after the student completes more than 60% of the payment period, the student earns 100% of the federal financial aid funds.

Diploma Programs (except Vocational Nursing) and all Degree Programs

The percentage of the period completed is calculated as follows:


Number of calendar days completed in the payment period or period of enrollment


Total number of calendar days in the payment period or period of enrollment


Total Calendar Days Completed in the Payment Period or Period of Enrollment

The total number of calendar days completed in the payment period or period of enrollment (numerator) is the count of calendar days from the start date of the payment period or period of enrollment to the student’s last date of attendance. Calendar days are removed from calendar days completed in the payment period or period of enrollment if any of the following occurred between the payment period or enrollment period start date and the student’s last date of attendance:

  • Institutionally scheduled breaks of five (5) consecutive calendar days or more
  • Holidays
  • Inclement weather
  • Administrative
  • Student scheduled or selected breaks of five (5) consecutive calendar days or more between courses
  • All approved Leave of Absence calendar days

Total Calendar Days in the Payment Period or Period of Enrollment

The total number of calendar days in a payment period or period of enrollment (denominator) is determined based upon the number and type (credential level and modality) of credits awarded in the payment period or period of enrollment. Calendar days are removed from the calendar days in the payment period or period of enrollment, if any of the following occurred or is scheduled to occur from the start date of the payment period or enrollment period to the end date of the payment period or enrollment period:

  • Institutionally scheduled holiday breaks of five (5) consecutive calendar days or more
  • Student scheduled of selected breaks of five (5) consecutive calendar days or more between courses
  • All approved Leave of Absence calendar days
  • Periods of non-enrollment of five (5) consecutive calendar days or more due to administrative and inclement weather closures

Vocational Nursing (VN) and Dental Assisting (DA)

The percentage of the period completed is calculated as follows:

Number of scheduled hours completed in the enrollment period


Total number of scheduled hours in the enrollment period


Total Scheduled Hours Completed in the Enrollment Period

The total number of scheduled hours completed in the enrollment period (numerator) is the count of scheduled hours from the ;enrollment period start date to the student’s last date of attendance.

Total Scheduled Hours in the Enrollment Period

The total number of scheduled hours in a enrollment period (denominator) is determined based upon the number of scheduled hours in the enrollment period.

Calculation Examples

The following examples illustrate the calculations outlined above. The figures provided are examples only; actual amounts may vary for each student/program.

Medical Assistant Example - illustrative purposes only.

Enrollment Period is 8/27/21 to 6/23/22.  Last documented date of attendance was 12/16/21. Scheduled breaks of 5 days or more: 12/19/21 – 1/5/22; 11/25/21 – 11/30/21; 1/13/22 – 1/28/22.


Module Start Date End Date Grade
MA100 8/27/21 9/24/21 B
MA200 9/29/21 10/26/21 A
MA300 10/28/21 11/24/21 C
MA400 11/30/21 1/12/22 W
MA500 1/28/22 2/25/22
MA600 2/29/22 3/25/22
MA700 3/29/22 4/25/22
MA EXT 4/27/22 6/23/22
Module: MA100
Start Date 8/27/21
End Date 9/24/21
Grade B
Module: MA200
Start Date 9/29/21
End Date 10/26/21
Grade A
Module: MA300
Start Date 10/28/21
End Date 11/24/21
Grade C
Module: MA400
Start Date 11/30/21
End Date 1/12/22
Grade W
Module: MA500
Start Date 1/28/22
End Date 2/25/22
Module: MA600
Start Date 2/29/22
End Date 3/25/22
Module: MA700
Start Date 3/29/22
End Date 4/25/22
Module: MA EXT
Start Date 4/27/22
End Date 6/23/22


Number of calendar days completed in the enrollment period = 75


Total number of calendar days in the enrollment period = 265


Percentage of the enrollment period completed = 28.3%

Vocational Nursing Example - illustrative purposes only.

Enrollment Period is 8/5/2019 to 3/12/2020. Last documented date of attendance was 11/18/2019.


Module Start Date Scheduled Hours End Date Grade
VOCN100 8/5/2019
10/22/2019 B 82
VOCN100L 8/8/2019 10/24/2019 PASS 120
ANA100 8/19/2019 10/28/2019 A 30
8/28/2019 10/30/2019 C 30
VOCN100C 9/26/2019 10/25/2019 PASS 60
VOCN200 11/4/2019 1/17/2020 W 23
PSYCH1 11/7/2019 1/9/2020 W 8
PHARM1 11/8/2019 1/10/2020 W 8
VOCN200C 11/11/2019 1/13/2020 W 30
VOCN210C 1/10/2020
1/14/2020 1/28/2020
VOCN300 2/3/2020 4/7/2020
VOCN300C 2/5/2020 4/2/2020
PHARM2 2/7/2020 4/10/2020
Module: VOCN100
Start Date 8/5/2019
Scheduled Hours 10/22/2019
End Date B
Grade 82
Module: VOCN100L
Start Date 8/8/2019
Scheduled Hours 10/24/2019
End Date PASS
Grade 120
Module: ANA100
Start Date 8/19/2019
Scheduled Hours 10/28/2019
End Date A
Grade 30
Module: VOCN110
Start Date 8/28/2019
Scheduled Hours 10/30/2019
End Date C
Grade 30
Module: VOCN100C
Start Date 9/26/2019
Scheduled Hours 10/25/2019
End Date PASS
Grade 60
Module: VOCN200
Start Date 11/4/2019
Scheduled Hours 1/17/2020
End Date W
Grade 23
Module: PSYCH1
Start Date 11/7/2019
Scheduled Hours 1/9/2020
End Date W
Grade 8
Module: PHARM1
Start Date 11/8/2019
Scheduled Hours 1/10/2020
End Date W
Grade 8
Module: VOCN200C
Start Date 11/11/2019
Scheduled Hours 1/13/2020
End Date W
Grade 30
Module: VOCN210C
Start Date 1/10/2020
Scheduled Hours 1/29/2020
Module: VOCN210C
Start Date 1/14/2020
Scheduled Hours 1/28/2020
Module: VOCN300
Start Date 2/3/2020
Scheduled Hours 4/7/2020
Module: VOCN300C
Start Date 2/5/2020
Scheduled Hours 4/2/2020
Module: PHARM2
Start Date 2/7/2020
Scheduled Hours 4/10/2020


Number of scheduled hours completed in the enrollment period = 391


Total number of scheduled hours in the enrollment period = 900


Percentage of the enrollment period completed = 43.4%

AOS Respiratory Therapy Example - illustrative purposes only.

Payment Period is 2/5/22 to 4/14/22.  Last documented date of attendance was 3/8/22. There were no scheduled breaks of 5 days or more. 

Number of calendar days completed in the payment period = 33


Total number of calendar days in the payment period= 70


Percentage of the payment period completed = 47.1%

Title IV Credit Balance and the Return Calculation

A Title IV credit balance created during the after the last date of attendance is not released to the student nor returned to federal financial aid programs prior to performing the R2T4 calculation. The College holds these funds even if, under the 14-day credit balance payment requirements, funds are otherwise required to be released.  In the R2T4 calculation, the College includes any federal financial aid credit balance as disbursed aid. Although not included in the R2T4 calculation, any federal financial aid credit balance from a prior payment period in the academic year that remains on a student’s account when the student withdraws is included as federal financial aid funds for purposes of determining the amount of any final federal financial aid credit balance when a student withdraws.  Upon application of any applicable refund policies, a federal financial aid credit balance is allocated first to repay grant overpayments owed by the student as result of the current withdrawal.  Within 14 days of the date that the College performs the R2T4 calculation, the College pays any remaining federal financial aid credit balance in one or more of the following ways:

  • in accordance with regulations to pay authorized charges at the College (including previously paid charges that are now unpaid due to a return of Title IV funds by the College)
  • in accordance with instructions provided by the student (and parent for a PLUS loan) on the mostly recently submitted ‘Authorization to Retain Funds Form’ or other written instructions to reduce the student’s loan debt (not limited to loan debt for the period of withdrawal).  In the absence of a signed ‘Authorization to Retain Funds Form’ or other written instructions, the College pays the credit balance to the student (or parent for a PLUS loan).  
  • If the College is unable to locate the student (or parent) when attempting to pay a credit balance to the student (or parent), it returns the funds to federal financial aid programs.

Return of Unearned Aid

In the R2T4 calculation, the total Amount Disbursed plus Amount that Could Have Been Disbursed to the student or on the student’s behalf, minus the Amount of Federal Financial Aid Earned by the Student determines the amount of federal financial aid funds that are “unearned” and therefore required to be returned to the funding source.  When a return of federal financial aid is required, the College and the student may both need to return funds. The College returns the lesser of the following amount to the appropriate federal financial aid program(s):

  • The total amount of unearned aid; or
  • The amount equal to the total College charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of unearned aid.

College (institutional) charges incurred by the student include tuition, fees, books and supplies initially assessed the student for the entire payment period or period of enrollment. Initial charges are only adjusted for changes the College makes prior to the student’s withdrawal. The amounts of institutional charges included in the R2T4 calculation are those charged or anticipated to be charged to the student’s account. Although institutional charges may not have actually been charged due to the student’s withdrawal, the College uses the actual charges to date, to include full tuition, fees, books and supplies for each course in the payment period or period of enrollment, and estimates remaining charges based on the students’ program. If after the student withdraws, the College changes the amount of institutional charges it assessed, or decides to eliminate all institutional charges, those changes do not impact the charges or aid earned in the calculation.  The College returns federal financial aid funds to programs in the following order up to the net amount disbursed from each:

  • Unsubsidized FFEL/Direct Unsubsidized Loan
  • Subsidized FFEL/Direct Subsidized Loan
  • Federal Direct PLUS (Parent of Dependent Student)
  • Federal Pell Grants
  • Iraq & Afghanistan Service Grant (IASG) 

After the College allocates its portion of unearned funds, the student must return federal financial aid owed in the same order specified above for the College. The amount of federal financial aid the student is responsible for returning is calculated by subtracting the amount returned by the College from the total amount of unearned federal financial aid funds to be returned.  The student (or parent in the case of funds due to a parent PLUS Loan) must return or repay, as appropriate, the calculated amount to any federal financial aid loan program in accordance with the terms of the loan; and any federal financial aid grant program as an overpayment of the grant. The amount of a grant overpayment due from a student is limited to the amount by which the original grant overpayment exceeds one-half of the total federal financial aid grant funds received by the student.  The College may round final repayment amounts, for which the College and student are responsible, to the nearest dollar.

Timelines for Return of Funds

The College completes a student’s R2T4 calculation within 30 days of the College’s date of determination. The College returns the amount of federal financial aid funds for which it is responsible as soon as possible but no later than 45 days after the date the College determines the student has withdrawn.

Deceased Student

If the College receives reliable information indicating an individual borrower or student for whom a parent received a PLUS Loan dies, the College suspends further awarding and disbursements.  An original or certified copy of the death certificate or accurate and complete photocopy of the original or certified copy of the death certificate is requested and forwarded to the Department of Education. Under exceptional circumstances and on a case-by-case basis, the Department of Education may approve a discharge based upon other reliable documentation supporting the discharge request.


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