Title IV funds (i.e., federal financial aid) are packaged for a student under the assumption that the student will attend school for the entire period for which the aid has been awarded. At APUS, this determination is made on a semester basis.
When a student who has received, or is otherwise eligible for, Title IV funds is considered withdrawn from a semester under this policy, the university is required by law to perform a Return of Title IV Funds (R2T4) calculation to determine the percentage and amount of aid that the student earned up to the time of withdrawal. The outcome of an R2T4 calculation may result in APUS’s determination that a student owes funds to the university, the federal government, or both. An R2T4 determination cannot be appealed.
Federal law requires schools to calculate how much federal financial aid a student has earned if that student:
- Officially withdraws from the school (i.e., begins the official withdrawal process or provides official notification of intent to withdraw), or
- Officially withdraws from all module(s) with a confirmation to continue in a later module(s) in the semester but does not continue in the later module(s).
- Unofficially withdraws from the school (e.g., stops attending classes before completing the semester), or
Unless the student is enrolled in a program offered in modules and:
- Completes half-time course enrollment in a semester with passing grades, or
- Completes one module (i.e., course) that includes 49% or more of the number of days in the payment period with a passing grade
- Completes a combination of modules that when combined contain 49% or more of the number of days in the payment period with a passing grade (excluding scheduled breaks of five or more consecutive days and all days between modules)
Students who elect to withdraw (disenroll) from the university during a semester must do so by dropping or withdrawing from all their courses in the semester and then completing the Disenrollment Request Form or otherwise contacting the Registrar’s Office to initiate the withdrawal process.
A student is considered an official withdrawal if they have:
- Dropped and/or withdrawn from all courses and either do not plan to continue in the current semester or no longer have the opportunity to add registrations
- Dropped and/or withdrawn from all active courses, student selected confirmation to continue but did not continue and was identified by APUS at the mid-point in the semester
- Been Dismissed/Expelled during an active semester
- Voluntarily Disenrolled during an active semester by submitting a Disenrollment Request Form to the Registrar’s Office or otherwise contacting the Registrar’s Office to initiate the withdrawal process
Unless the student is enrolled in a program offered in modules and:
- Completes half-time course enrollment in a semester with passing grades, or
- Completes one module that includes 49% or more of the number of days in the payment period with a passing grade
- Completes a combination of modules that when combined contain 49% or more of the number of days in the payment period with a passing grade (excluding scheduled breaks of five or more consecutive days and all days between modules)
If a student who began attendance, and has not officially withdrawn, fails to earn a passing grade in at least one course offered over the entire semester, the university must assume for Title IV purposes that the student has withdrawn. The student may then be subject to an R2T4 calculation, unless the school can document that the student completed the period.
- The university differentiates between an earned F and an unearned F grade based on the fulfillment of course requirements — an earned F grade is not considered a withdrawal.
- Students determined to be an unofficial withdrawal are no longer considered enrolled for the semester and are therefore subject to R2T4 rules.
Students are required to log into all courses and complete an academic activity during Week One. Specifically, students must submit a minimum 250-word introductory forum post for each course. Students who do not complete this activity during the first week of class will be administratively dropped for “non-attendance” from any courses in which this assignment has not been completed.
If a student is administratively dropped from all courses for non-attendance prior to the census date, the student is not eligible for Title IV program funds, and all Title IV funds will be returned.
Modules are courses that do not span the entire payment period (semester); an example of a module is an 8-week class within a 16-week semester. A student in a module-based program would be considered withdrawn if the student:
- Does not complete all the days they were required to attend the module(s) during the semester for which their aid was intended
- Confirms intention to return for another module in the same semester but does not return
Unless the student
- Completes half-time course enrollment in a semester with passing grades, or
- Completes one module that includes 49% or more of the number of days in the payment period with a passing grade
- Completes a combination of modules that when combined contain 49% or more of the number of days in the payment period with a passing grade (excluding scheduled breaks of five or more consecutive days and all days between modules)
Students may provide written confirmation at the time of withdrawal that he or she will attend a module that begins later in the same semester. A student is not considered to have withdrawn if the university obtains a written confirmation to continue on the withdrawal form at the time of the withdrawal. Future semester registrations are not considered a confirmation to continue.
Students who do not confirm future enrollment, but return to a module within the same semester, will be treated as if they are not withdrawn. The Return of Title IV Funds calculation will be reversed.
Drops Prior to a School's Freeze Date
The “Freeze Date” only applies to R2T4 calculations and is not the same as the semester census date. APUS’s freeze date is the 2nd Tuesday of the third month of each semester. APUS applies the Freeze date within R2T4 calculations per Department of Education guidelines and regulations.
R2T4 calculations are completed within 30 days of the Date of Determination that a student withdrew (DOD). Students receive electronic notifications of the R2T4 calculation and results. The following R2T4 procedures are followed:
- The amount of aid earned is based on a determination of the withdrawal date, which may be:
- For unofficial withdrawals, either the midpoint of the semester or the last documented date of attendance at an academically related activity, whichever is later.
- For official withdrawals, either the last course drop/withdrawal date or date of disenrollment as provided to the Registrar.
- The institution will determine the last date that the student participated in an academically- related activity such as participating in a discussion group, taking a quiz or exam, turning in homework, etc.
- Simply logging into a course without active participation does not constitute an academically related activity.
- Up through the 60% point in each payment period (semester), a pro rata schedule is used to determine how much in Title IV funds the student has earned at the time the student is considered withdrawn.
- After the 60% point in the payment period, a student has earned 100% of the Title IV funds.
- The percentage of the payment period completed is determined by dividing the number of calendar days completed in the payment period as of the day the student withdrew by the total number of calendar days in the same period.
- Scheduled breaks of five or more consecutive days are excluded from the R2T4 calculation. If a scheduled break occurs prior to a student’s withdrawal, all days between the last scheduled day of classes before a scheduled break and the first day classes resume are excluded from the total number of calendar days in a payment period (denominator) and the number of calendar days completed in that period (numerator). If the withdrawal occurs prior to a scheduled break, the days in the break are excluded only from the denominator.
If a student earned more aid than was disbursed, they may be owed a post-withdrawal disbursement (PWD). PWD determinations are made and offered to the student within 30 days after the DOD. If accepted, Pell PWDs are made no later than 45 days after the DOD. Loan PWDs are made within 180 days after the DOD.
Students are provided a PWD form that identifies a “response due date” of 14 days from the date of notification. If a response is received by the due date, the PWD is initiated and monitored through posting on the student’s ledger. If the student has an FSA credit balance once all funding has processed, the credit balance is processed according to the student’s credit balance selection.
Title IV (Federal Student Aid) funds credited to outstanding loan balances for the payment period for which a return of funds is required must be returned in the following order:
- Unsubsidized Direct Loans (other than Direct PLUS loans)
- Subsidized Direct Loans
- Direct PLUS Loans (parent or graduate)
If funds remain after repaying all loan amounts, those remaining funds must be credited in the following order for the payment period for which a return of funds is required:
- Federal Pell Grants
- Iraq and Afghanistan Service Grants
- Federal Supplemental Educational Opportunity Grant (FSEOG)
- Other assistance under Title IV for which a return of funds is required
The university is required to return the amount of Title IV funds for which it is responsible no later than 45 days after the date of the determination that a student is withdrawn. Students who have FSA funds returned and owe money to the institution are notified by e-mail and a ‘Balance Due Hold’ is placed on the account.
For students who require an R2T4 calculation, documentation is compiled and maintained as part of the student record and financial aid file.
In accordance with Department of Education (ED) guidance on R2T4 requirements during payment periods that include or occur between March 13, 2020, and the later of December 31, 2020, or the last date the national emergency, APUS has applied the following towards verified Covid-19 related withdrawals:
- All pending disbursements will be made and considered disbursed prior to the DOD.
- For all disbursements students receive during the payment periods in which they withdrew due to Covid-19, APUS will add a Coronavirus indicator in COD.
- Regardless of the R2T4 calculation outcome, no funding is returned to the Department of Education as the result of the R2T4.
- Any amounts not returned under R2T4 requirements due to CARES Act will be reported to ED.