ED OPE UPDATES RETURN TO TITLE IV QUESTIONS AND ANSWERS

It’s been a while since the Program Integrity Questions and Answers page was updated, but last month the Department updated the Frequently Asked Questions page with updates on the new Withdrawal and R2T4 rules that took effect on July 1, 2021. The rules made updates to several regulations:

Updated the order of return (for both institution and student returns) to require returns of Iraq-Afghanistan Service Grants prior to returns of Federal Supplemental Educational Opportunity Grant (FSEOG) and Teacher Education Assistance for College and Higher Education (TEACH) Grant funds;

Expanded the approved leave of absence (LOA) definition to incorporate subscription-based programs;

Expanded the definitions of “academic attendance” and “attendance at an academically-related activity” to refer to the new definition of “academic engagement” found under 34 CFR 600.2;

Updated the definition of a “program offered in modules” to apply only to standard and nonstandard term programs that are not subscription-based;

Amended the timeframe associated with when a student is considered withdrawn if not scheduled to begin a new course in a non-term or subscription-based program;

Amended the written confirmation timeframe associated with when a student is scheduled to resume attendance later in the period for students in non-term or subscription-based programs;

Exempted students who graduate or complete all requirements for graduation from the R2T4 requirements;

Exempted students in term-based programs that do not use subscription periods from R2T4 requirements if they cease attendance after successfully completing a module or combination of modules that include 49 percent or more of the number of days in the payment period;

Exempted students in term-based programs that do not use subscription periods from R2T4 requirements if they cease attendance after successfully completing coursework equal to or greater than the coursework required for the institution’s definition of a half-time student under 34 CFR 668.2;

Amended the requirements for establishing the total number of days in the payment period or period of enrollment (denominator) of the R2T4 calculation to only include the days in a module if the student attended the module or the student’s coursework in that module was used to determine the amount of the student’s eligibility for Title IV, HEA funds for the payment period or period of enrollment; and

Allowed institutions to use an “R2T4 Freeze Date” to establish the number of days in the denominator of the R2T4 calculation based on the student’s enrollment on a specific date.