Return of Title IV Funds

When a student who is receiving Title IV Financial Aid withdraws from South Dakota State University (SDSU or the university), federal laws and regulations require SDSU to determine how much Federal Title IV Aid the student has earned for the term and to return any unearned Federal Financial Aid funds. This process is called the Return of Title IV Funds. The Return of Title IV Funds Process is the part of the university’s withdrawal process.

Section 484B of the Higher Education Act of 1965, as amended, provides the statutory basis for the treatment of Title IV Financial Aid when a student who is receiving Title IV Financial Aid withdraws from the university.

The Return of Title IV Funds Policy is separate from the University’s Refund Policy which is articulated by the South Dakota Board of Regents. The University’s Refund Policy applies to students who withdraw from the university, but the refund amount is determined outside of the Financial Aid Office and does not impact the Return of Title IV Funds calculation.

Students are eligible to receive all “earned” financial aid even if the university provides a 100 percent refund of charges. For example, students who withdraw prior to the census date will receive a 100 percent refund of tuition and fees, but they will still earn a portion of their Title IV Financial Aid for attending even one day.

Students who withdraw early in the semester may request a cancellation of all Title IV Aid. This is especially common with students who decide to attend a different school for the same term and who wish to use their Federal Loans and Grants at that school. In these situations, the Financial Aid Office Policy is to cancel all of the financial aid the student received for the term as long as the request is received in writing either through the student’s jack’s email account or a signed statement.

Students who complete 60 percent or more of their scheduled days are considered to have earned 100 percent of their Title IV funds. If a student who has completed 60 percent of the scheduled days withdraws, the Financial Aid Office must still review the students file to determine if the student is owed a post-withdrawal-disbursement.

SDSU is also required to provide students with consumer information related to the withdrawal and Return of Title IV Funds Process.

SDSU offers courses in credit hours and standard terms. For credit hour programs generally, a student is considered to have withdrawn when the student does not complete all of the days the student was scheduled to complete for a given term or semester.

The scheduled days refer to days that are included in Title IV eligible courses. Consequently, if a student remains enrolled in only courses that are not eligible for Title IV (such as courses that have been repeated more than 1 time after receiving a passing grade), the student is considered to have withdrawn for Return of Title IV Funds purposes. Additionally, when looking at modular courses, courses that are not eligible for Title IV Aid should not be included in the scheduled days.

In certain situations, students who do not complete all of the days they were scheduled to complete are exempt from Return of Title IV Funds/withdrawal processing. These exemptions are discussed later in this section and they primarily pertain to courses that are taken in modules.

The rules for determining if a student withdrew vary depending on whether or not the student was scheduled to attend at least one course that is offered in modules. Modular courses are courses that do not span the entire payment period. At SDSU, most summer courses are offered in modular sections that span only a portion of the summer term, while most courses in the fall and spring terms run the entire length of the terms.

The policies in this document cover both withdrawals from courses that span the entire term and withdrawals from modular courses. A standard withdrawal will refer to a withdrawal that is processed for a student enrolled in only Title IV eligible courses that are not modular and that span the entire length of the term. Withdrawals that involve any Title IV eligible modular courses will be called modular withdrawals. If student is enrolled in both modular courses and courses that span the entire length of the term withdraws, the withdrawal will be treated as a modular withdrawal with the full-term course being treated as a modular course that spans the entire length of the term.

There is a difference between a withdrawal and a change in enrollment status. Students who drop some but not all of their Title IV-eligible courses after the start of the term may have a change in enrollment status, but they are not considered to be withdrawn unless the courses are modular, the student is no longer scheduled to complete all of the days the student was scheduled to complete and the student does not qualify for an exemption (see below).

Additionally, a student who does not start attendance in any of the courses for the term is not considered to be withdrawn for Return of Title IV purposes, even if that student later petitions SDSU to be removed or withdrawn from all of the courses in the term. Students who do not start attendance are not eligible for any Title IV Aid and must have all of their Title IV Aid unpaid.

For standard withdrawals, a student is considered to have withdrawn if the student does not complete all of the days the student was scheduled to attend in the semester or term. The one exemption for standard withdrawals is for a student who completes their program of study during the same semester or term. See additional discussion of this exemption in the modular withdrawal exemptions listed below.

For modular withdrawals, students are also considered to have withdrawn from the term if the student does not complete all of the days the student is scheduled to attend in the term. There are several exemptions for modular withdrawals. These are

1. The student completes the program of study during the term/semester.

   An example of this would be a student who needs only 2 three-credit courses to complete the program of study. The student enrolls in the courses and also petitions to have courses taken at a different school be used to fulfill the requirements. When the petition is approved, the student stops attending the courses. As long as the student completes the program of study the same term, this situation would not require a Return of Title IV Funds calculation.

   This would not apply to a student who changed to a different program of study after the Title IV aid was disbursed. For example, a student enrolled in a Bachelor’s program who switches (after the aid has disbursed) to an Associate’s Degree and then withdraws because the student has already met the requirements for the Associate’s Degree would still need to have the Return of Title IV Funds calculation completed.

   This exemption applies to both standard withdrawals and modular withdrawals.

2. The student successfully completes at least half-time enrollment during the term (6 undergraduate credits and 5 graduate level credits).

   For example, a student enrolls in 9 credits in the summer session. 3 of the credits span the entire 12-week summer session and 6 of the credits span just the first 5 weeks. The student completes one 5-week course with a B and one with a D. The next day the student decides to withdraw from the remaining 3 credits in the 12-week session. Since the student successfully completed courses with credits that total at least half-time, the student is exempt from the Return of Title IV Funds calculation.

   Please note that if the student in the example in the paragraph above received an F in one of the courses, it would not be considered “successful” completion, and the student would then be subject to Return of Title IV Funds calculation. Even if the failing grade is “earned” with a student attending through the end of the course, it does not count as successful completion (See September 2, 2020 Federal Register).

   For any modular withdrawals where a student received in incomplete grade that if passed would result in the student completing at least half-time enrollment or 49 percent of the countable days (see exemption 3 below), the financial aid administrator responsible for reviewing withdrawals will need to check the status of the Incomplete grade up through day 45 to ensure that any necessary corrections are made. This exemption is only for modular withdrawals.

   The rules for counting courses that receive in Incomplete grade follow:

   1. If a student receives an incomplete grade in a course and the grade is not updated before the Return of Title IV Funds Calculation has been completed, the course does not count as successful completion for the exemption.
   2. If the student completes the course after the Return of Title IV Funds calculation but within 45 days of the withdrawal date, then the Return of Title IV Funds Calculation must be corrected if the student now meets the requirements for the exemption.

      For example, if the student had an incomplete grade at the time of withdrawal and then receives a passing grade in the course before day 45 and that grade results in the student completing at least half-time enrollment, the student would no longer be considered a withdrawal and the Return of Title IV would need to be reversed.

   3. If the student completes a course after the 45^th day, then the original Return of Title IV Funds Calculation remains and the student does not meet the exemption requirements.
3. The student successfully completed courses in modules spanning 49 percent or more of the payment period. The payment period is the term or semester.

   To determine if the student has completed 49 percent of the days in the payment period, you must determine the number of countable days in that payment period and the number of those days in the modules that the student completed.

   To find the number of countable days in the payment period, count the number of days in the payment period excluding scheduled breaks of 5 days or more and all of the days between modules. If there are overlapping modules that span the weekends between some modules, you would not exclude the weekends from the countable days. A class that spans the full-term would be counted as a module that spans the entire term. See Section 13.3 below for policy related to counting days.

   Then determine how many of those days were included in the modules that the student successfully completed. Divide the number of days in the modules the students successfully complete by the number of days in the payment period. If the result is 49 percent or more, the student is exempt from the Return of Title IV Funds calculation.

   Please note that this third exemption also references only countable days in courses that are successfully completed with a passing grade (D or better). The same rules for incomplete grades that are listed above for students who are exempt due to completing half-time enrollment apply to this exemption.

   Also, the student must complete 49 percent of the countable days in the payment period not 49 percent of the days the student was scheduled to complete in that payment period. These countable days are used only to determine if the student qualifies for the exemption. The actual Return of Title IV Funds Calculation will be based on the percentage of days the student completed based on the days the student was scheduled to complete.

   This exemption is only for modular withdrawals.

4. Written confirmation that the student will attend a subsequent module

   If at the time the student withdraws from modular courses, the student provides written confirmation that the student will attend a future module that starts no later than 45 days after the date the student withdrew, then the student is not considered to have withdrawn.

   If however, the student does not return as indicated within 45 days, the student is considered to have withdrawn, and the Return of Title IV Funds calculation must be completed.

The exemptions are not optional. Consequently, the financial aid administrator must review each withdrawal in all terms to ensure that the student’s situation does not meet one of the exemptions.

The U.S. Department of Education’s Common Origination and Disbursement System (COD) categorizes withdrawals into six different types of withdrawals. These include

1. Official
2. Expressed Intent
3. Unofficial
4. No Notification/Circumstances beyond the student’s control
5. Unapproved
6. Last date of an academically-related activity

The financial aid administrator responsible for calculating the Return of Title IV Funds for a student must, as part of that process, decide which category the withdrawal falls into and must input that information into the U.S. Department of Education’s Return of Title IV Funds calculator.

The majority of the withdrawals processed at SDSU fall into the Official Withdrawal and Unofficial Withdrawal categories. A smaller number of withdrawals will fall into the other categories. The one exception is the Unapproved category. SDSU does not currently have a Leave of Absence policy. Consequently, the Unapproved Withdrawal for students who do not return from a leave of absence is not used at SDSU.

The following describes the withdrawal categories used by SDSU and the circumstances where each category would be used:

1. Official Withdrawals

   Official withdrawals are those that result from students initiating the official withdrawal process with the SDSU Registrar’s Office. This process can be initiated by contacting the SDSU Registrar’s by email, by phone, or by stopping by the Registrar’s Office and notifying someone in the Registrar’s Office in-person. There is one person in the Registrar’s Office who is designated as the primary contact to do intake for and initiate the processing of withdrawals, but all of the other staff members in the Registrar’s Office are authorized to initiate the process when the primary contact is absent or not available to meet with students.

   The University establishes a last date to withdraw in each term. This date usually coincides with the 60 percent point of the term. Students who wish to withdraw from a term after the last date to withdraw has passed or who want to request a refund that is above what is allowed by the University’s Refund Policy, must complete a Petition to Withdraw. The petition can be found online on the Registrar’s Forms page. Students who submit the Petition to Withdraw are also considered to be initiating an official withdrawal.

   At times, students will submit a Petition to Withdraw that is not actually a withdrawal. For example, a student who did not start any courses in the term, but did not officially withdraw before the census date, may submit the petition to request a refund of all charges for the term. Since this student did not start any courses, all financial aid would be returned, and the student’s financial aid would not be subject to the Return of Title IV Funds calculation. The decision as to whether or not a Petition to Withdraw requires a Return of Title IV Funds calculation is made by the Financial Aid Office not the Registrar’s Office.

2. Otherwise Provided Official Notification/Expressed Intent Withdrawals

   A student may contact the Registrar’s Office without initiating the official withdrawal process and notify the Registrar’s Office of their intent to withdraw. These types of withdrawals would be categorized as Otherwise Provided Official Notification/Expressed Intent Withdrawals.

   For example, a student may contact the Registrar’s Office and ask about the process to withdraw letting the Registrar’s Office know that they will be withdrawing in two weeks because they are being deployed. The student would be considered to be providing official notification of intent to withdraw and a withdrawal should be started for the student since the student has expressed intent to stop attending before the end of the term.

   Note, however, that a student who contacts the Registrar’s Office to inquire about the withdrawal process because they are considering withdrawing, are not considered to be initiating the official withdrawal process.

3. Unofficial Withdrawals

   When a student who could have officially withdrawn leaves the University without providing notification, these are categorized as Unofficial Withdrawals on the U.S. Department of Education’s Return of Title IV Funds Worksheet. The majority of Unofficial Withdrawals are identified at the end of each term when the Financial Aid Office runs reports to identify students who did not pass any of their classes for the term through the All F Review process. As part of this process, the Financial Aid Office researches if the students “earned” their failing grades by attending through the end of the term or if they received failing grades because they unofficially withdrew.

4. Circumstances Beyond the Student’s Control (No Notification)

   A student may also stop attending the University and, due to circumstances beyond the student’s control and not be able to initiate the official withdrawal process or notify the University of intent to withdraw. In these situations, the unofficial withdrawal will need to be categorized as No Notification/Circumstances Beyond the Student’s Control. This would include situations where a student is hospitalized, incarcerated, injured, seriously ill, or suffers a grievous personal loss. Students who pass away while attending also fall into this category.

   Situations where a student is administratively withdrawn by the University for failure to pay a bill, conduct, or other reason are also categorized as No Notification/Circumstances Beyond the Student’s Control Withdrawals. Generally, decisions to administratively withdraw students are made in the Office of the Vice President of Student Affairs or the Cashier’s Office.

5. Last Date of an Academically Related Activity

   SDSU is not required to take attendance, but the Financial Aid Office has the option to use as the student’s last date at an academically related activity as the withdrawal date for the Return of Title IV Funds Calculation. When this date is used the withdrawal should be categorized as Last Date of an Academically-Related Activity on the Return of Title IV Funds worksheet. The financial aid administrator who processes the Return of Title IV Funds calculation must determine when the last date of academic activity should be used.

The Return of Title IV Funds requirement is a complex process that involves cooperation between multiple offices on campus including the Registrar’s Office, Financial Aid, and the Cashier’s Office. Housing and the Card Services are involved in the University withdrawal process, but their processing does not impact the Return of Title IV Funds calculation and, therefore, is not described in detail in this document.

The Registrar’s Office (also called the Records Office or the Records and Registration Office) is the office the University has designated for students to contact to initiate the official withdrawal process or to express their intent to withdraw. Students must call, email, or stop by the Registrar’s Office to initiate the withdrawal process.

Additionally, when students are administratively withdrawn by the University or the University is notified that a student has withdrawn and is not able to officially withdrawal, the withdrawals will be initiated through the Registrar’s Office. Student’s Petitions to Withdraw are also initiated with the Registrar’s Office.

When a student withdraws from the University (either through official withdrawal, expressed intent, Petition to Withdraw, administrative withdrawal, or no notification withdrawal), the Registrar’s Office starts the withdrawal process. Currently, that process involves an electronic form that is routed to the different offices on campus who are part of the withdrawal process.

The Registrar’s Office is also responsible for updating the student’s academic records and the Student Information System to indicate that the student withdrew, maintaining a copy of the withdrawal documentation, and reporting the withdrawals to the National Student Loan Data System.

The Cashier’s Office also plays an important role in the Return of Title IV Funds Process. In the interest of timing, the Financial Aid Office determines which charges should be included in the Return of Title IV Funds Calculation, but the Cashier’s Office reviews those charges and ensure that the correct charges were used. If incorrect charges were used, the Cashier’s Office must notify the Financial Aid Office before the 45th day from the date of determination of withdrawal so the calculation can be corrected timely.

When a post-withdrawal disbursement is made to a student, the Financial Aid Office initiates the disbursement to post the funds to the student’s account. The Cashier’s Office, however, is responsible for ensuring that Title IV funds post only to institutional charges and other educational charges authorized by the student and for refunding Title IV funds to students within the federal timelines.

Once the funds are unpaid from the student’s account (through the Financial Aid disbursement process), the transactions flow from the Banner Student system over to the Banner Finance system creating a credit in the accounts for the federal funds that were paid and returning the funds to the University’s federal funds bank account. The Grants Office is responsible for managing these funds and for applying the cash management rules that determine when funds must be returned to the G5 account.

Any student who has received a Title IV Grant or Loan for the semester/term is considered to be a Title IV recipient for the purposes of Return of Title IV Funds. The following types of financial aid qualify as Title IV Grants and/or Loans:

• Direct Unsubsidized Loans (excluding Direct PLUS Loans)
• Direct Subsidized Loans
• Direct Parent PLUS Loans and Graduate Plus Loans
• Federal Pell Grants
• Federal Supplemental Educational Opportunity Grants (SEOG)
• TEACH Grants

Federal Work-Study is Title IV financial Aid, but it is not subject to the Return of Title IV Funds. Consequently, when students who receive Federal Work-Study and no other Title IV funds withdraw, the Return of Title IV Funds process does not need to be completed (other than the review for possible post-withdrawal disbursements/aid that could have been disbursed).

SDSU no longer awards Federal Perkins Loans, Federal SMART Grants, and Federal Academic Competitiveness Grants. Consequently, these are no longer included in the Return of Title IV Funds process.

Other financial aid such as outside scholarships and grants, state funding, and institutional aid are not included in the Return of Title IV Funds calculation. When students who receive these types of awards withdraw, internal and external policies outside the scope of this document are followed to determine if the awards should remain paid or be returned.

There are several timeframes or deadlines that must be met when processing Return of Title IV Funds for students.

The University must return all unearned Title IV Funds as soon as possible but no later than 45 days after the date of determination of a student’s withdrawal. SDSU returns its funds by unpaying the unearned aid through the Banner disbursement process which in turn causes the funds to be deposited back into SDSU’s federal funds account.

All changes and corrections (see definitions below) to the Return of Title IV Funds calculation and any subsequent return of funds must be completed by day 45. Any updates based on changes or corrections that occur after that date will result in the Return of Title IV Funds being completed late.

Changes include updates to information that was correct when the calculation was initially completed. Updating changes is not required.

Corrections are updates to information in the calculation that must be made because they were incorrect at the time of the initial calculation. Entering the wrong amount for a grant or loan into the calculation, for example, would require a correction. Corrections must be made whether they are discovered before or after the 45-day timeframe. If they are made after day 45, then the Return of Title IV Funds will be considered late.

Additionally, for a student who qualifies for a Post-Withdrawal Disbursement, the University must, within 30 days of the date of the school’s determination that the student withdrew, notify the student or parent (in the case of a Parent PLUS Loan) of the availability of a post-withdrawal disbursement of funds. Although a small percentage of students qualify for a Post-Withdrawal Disbursement, the requirement that the student or parent be notified within 30 days requires the financial aid administrator who reviews withdrawals to have reviewed the withdrawal files on or before day 30 to identify any that may potentially have a post-withdrawal disbursement.

For unofficial withdrawals, a school that is not required to take attendance must determine the student’s withdrawal date within 30 calendar days of the earliest of the end of the payment period, period of enrollment, academic year, or the student’s educational program.

For example, if a student who is enrolled in courses that span the entire length of the term leaves SDSU during the term without officially withdrawing, the University has 30 days from the end of the term to determine that the student has withdrawn and to determine the withdrawal date.

If the same student was enrolled in modular courses, the University would have 30 days from the end of the student’s last scheduled class to identify that the student has withdrawn and to determine the withdrawal date.

Pell Recipients

Direct Loans are disbursed based on the student’s enrollment on the date of disbursement. If a student starts some but not all of the classes they were enrolled in at disbursement, the Direct Loans generally do not have to be unpaid even if the student starts courses that total less than half-time enrollment.

Pell Grant recipients have a different standard. Pell Grants are paid based on the credits the student is registered in on the Pell Recalculation Date. The only exception to this would be for students whose initial Pell calculation is performed after the Pell Recalculation date in which case the Pell disbursement is based on the credits at the time of the initial calculation. If a student does not start enough credits to receive the Pell award, the Pell must be recalculated to reflect a Pell payment based on the credits the student actually started.

For example, a student who is registered for 15 credit hours on the Pell Recalculation Date is paid a Pell Grant based on full-time enrollment. If that student only starts 9 of the credits, they are only eligible for a ¾ Pell and the Pell must be reduced to accurately reflect the credits they started.

If the same student registered for 15 credits but only started 12, no adjustment would be needed because the student started enough credits to equal full-time status.

Financial Aid sets the Pell Recalculation Date for the Fall and Spring terms to match the census date for courses that span the entire fall or spring term. The Pell Recalculation Date in summer is usually established as the first Friday after July 4.

Before processing the Return of Title IV Funds calculation for any student who received a Pell Grant during the term, the financial aid administrator must verify that the student started enough courses to receive the level of Pell funding that was disbursed. The research involves contacting professors to verify that students started courses. When available, the financial aid administrator may also access mid-term deficiency reports, Student Information System data, and other reports that document last dates of attendance in courses.

If the University cannot document that the student started enough courses, the Pell Grant must be reduced prior to the Return of Title IV Funds Calculation. Because of the limited window that SDSU has to process withdrawals, it is imperative that the Financial Aid Office be notified of withdrawals as soon as they are initiated so research can be conducted and completed timely.

The Financial Aid Office runs a report at the end of the term that helps identify students who received a Pell Grant and who did not start all of their courses. This process is outside the scope of this document as it does not involve Return of Title IV Funds.

Students Who Do Not Start Attendance in Any Courses

The section above describes the FAO policy for verifying attendance for students who receive Pell Grants. For all students, regardless of Pell-eligibility, the FAO must document that the student attended at least one course in the semester to qualify for any Federal Financial Aid. Before running a Return of Title IV Funds calculation for a student who has withdrawn, the FAO must have documentation to support that the student started academic attendance for the term.

The withdrawal documentation forwarded from the Registrar’s Office may include correspondence from instructors or other documentation to support that the student participated in academically-related activity during the term. If the documentation does not provide that evidence, the FAO will need to research and document that the student attended by checking reports such as deficiency lists where an instructor may have provided the last date a student attended class or by emailing instructors directly for that information.

Quality Control Checking

The Financial Aid Office has a policy of quality control checking each withdrawal that is processed. The quality control check involves a second individual, who was not involved in the initial Return of Title IV Funds Calculation, reviewing the Financial Aid Office’s portion of the withdrawal process including the Return of Title IV Funds Calculation for each student who withdraws.

This process must be completed on or before day 45 to ensure that any corrections to the Return of Title IV Funds calculation are made on or before day 45.

COVID 19 Waivers

As a result of the COVID-19 pandemic and subsequent federal legislation, several waivers were enacted related to Return of Title IV Funds calculations that resulted from pandemic-related withdrawals. As the waivers were a benefit to SDSU students, the University enacted the waivers mentioned in this section of the policy document.

The COVID-19 waivers were in effect for students who withdrew due to COVID-19 during covered payment periods which currently end with the payment period that includes March 2, 2022. As of December 2021, the covered payment periods include Spring 2020, Summer 2020, Fall 2020, Spring 2021, Summer 2021, Fall 2021, and Spring 2022.

For qualifying students, the waivers result in

• Cancellation of Direct Loan disbursements and TEACH Grant obligations for students who received disbursements during qualifying payment periods
• Exclusion of Pell Grant disbursements received during qualifying payment periods from Pell LEU
• Exclusion of subsidized Direct Loans from SULA
• Unearned aid received by both the student and the University not being returned to the U.S. Department of Education per the usual Return of Title IV Funds guidelines.

The Financial Aid Office is required to report the waivers by activating the COVID-19 flag on the Return of Title IV Funds Calculation Worksheet in COD and on the COD Direct Loan, Pell, IASG, and TEACH records that were impacted by the waivers. For the 19-20 school year which included spring 2020, the reporting was required to be completed by December 31, 2020. For the 20-21 and 21-22 school years the information must be reported on or before September 30, 2022.

The implementation of waivers has a different set of guidelines for terms where campus experienced an interruption in instruction and campus operations. During the spring 2020 semester, the University experienced an interruption in instruction and campus operations as the result of COVID-19. The interruption included

• Moving students from ground-based instruction to online learning
• Closing campus housing, dining, and other facilities
• An interruption in instruction with no classes held the week after spring break

Consequently, for Spring 2020 term, for students who were not enrolled as distance education students at the start of the spring 2020 term, federal guidance allowed SDSU to consider all withdrawals that term to be attributable to COVID-19. For students enrolled exclusively in distance education at the start of the term, the student had to provide the University with written attestation (including by email or text) that the withdrawal was due to COVID-19 in order for it to be considered due to COVID-19.

To date, no other term has qualified as one in which the campus experienced an interruption in instruction and campus operations.

For students who withdrew during the subsequent terms covered by the waivers (terms in which there was no interruption to instruction or campus operations), the student must have provided written confirmation that the withdrawal was due to COVID-19 in order for the withdrawal to be considered due to COVID-19.

If any of the following circumstances occurred as a result of COVID-19, the withdrawal could be attributed to COVID-19:

• illness of student or family
• need to become a caregiver or first responder
• loss of childcare
• economic hardship
• lack of access to wi-fi due to closed facilities
• increase in work hours due to COVID-19 emergency

Documentation to support the written attestation that the withdrawal was due to COVID-19 must be retained in the student’s file.

The withdrawal date is the date that is used to determine how much Title IV aid a student has earned. Consequently, the date must be correctly determined in order to accurately calculate the Return of Title IV Funds amounts for a student.

The withdrawal date is that used for Return of Title IV Funds Calculations does not have to be the same date that the University uses to determine the student’s refund, but it must be compliant with the federal regulations that govern withdrawals. When reporting withdrawal dates to the National Student Loan Data System (through Clearinghouse), the University must report the date that is used in the Return of Title IV Funds Calculation and not a separate date.

There are different rules for determining dates of withdrawal depending on whether or not a school or a specific program is required to take attendance. SDSU and its programs are not required to take attendance. Therefore, SDSU’s Return of Title IV Funds policy and procedures reflect those federal regulations and rules that pertain to schools who are not required to take attendance.

The date of the institution determines that the student has withdrawn is also an important date in the Return of Title IV Funds calculations.

The withdrawal date and the date of determination that a student has withdrawn for a school that is not required to take attendance varies depending on the type of withdrawal. The following describes the withdrawal dates and dates of determinations   for the types of withdrawals processed at SDSU:

• Official Withdrawals
  For a student who starts the official withdrawal process by contacting the Registrar’s Office, the withdrawal date is the date that the student begins the withdrawal process.
  
  The date that the institution determined that the student has withdrawn is the later of the student’s withdrawal date or the date of notification of withdrawal.

• Express Intent Withdrawals
  In the case of a student who expresses intent to withdraw in the future, the withdraw date is the date the student notifies the school of the intent to withdraw.
  
  The intent may be provided orally or in writing. If it is provided by a letter sent in the mail, the date of withdrawal is the date the University receives the letter.

  
  Keep in mind that a school may always use the last date of participation in an academic activity in lieu of the date the withdrawal process was initiated.
  
  Students who contact the Registrar’s Office to inquire about the withdrawal process but have not yet decided to withdraw are not considered to have expressed an intent to stop attending classes and should not be treated as withdrawals.

  If a student expresses intent to withdraw and starts the official withdrawal process on two different days, the earlier day should be used as the withdrawal date.

  The date that the institution determined that the student has withdrawn is the later of the student’s withdrawal date or the date of notification of withdrawal.

• Unofficial Withdrawals
  For Unofficial Withdrawals, the calculation is based on the midpoint of the payment period. Students who unofficially withdraw earn 50 percent of their Title IV Financial Aid.
  
  The only exception to this would be if SDSU determines that a student who received All Fs attended past the 60 percent point. In these cases, the student will be considered to have earned 100 percent of their Title IV aid for the term, and no Return of Title IV Funds Calculation will be performed. Documentation to support the last date of attendance will be maintained in the student’s file.

  When entering information in the Return of Title IV Funds Calculation, the withdrawal date entered should be the last day the student attended an academically related activity.  The date the school determined the student withdrew should be the date grades were finalized through term end grading.
  
  For standard withdrawals, the University has 30 days from the end of the term to identify students who have unofficially withdrawn and to establish their dates of withdrawal. For students who attend modular courses, the University has 30 days from the end of the last module the student attended in the term to identify students who have withdrawn and establish their dates of withdrawal.
  
  The Financial Aid Office runs reports during and at the end of the terms to identify students whose courses have ended and who have not received passing grades in any of their courses. The Financial Aid Office then researches the last dates that the students attended their classes to determine if the students earned their F grades by attending through the end of the term or if they have unofficially withdrawn.
  
  For students who receive all failing grades, the University must presume that the student unofficially withdrew unless the University can document that the student completed the payment period.
  
  If a student receives all F grades, the University should also ensure that the students started at least one course. If there is no documentation to support that a student started at least one course, all of the student’s financial aid for the term should be unpaid.

  The date that the institution determined that the student has withdrawn is the date the University became aware that the student has ceased attending.

• No Notification Withdrawals
  When a student stops attending and is not able to provide official notification due to circumstances beyond the student’s control, the school should determine a withdrawal date that most accurately reflects when the student ceased academic attendance to do the circumstances that are beyond the student’s control.
  
  In many cases, the date of withdrawal may be the day that the circumstance beyond the student’s control occurred.  For example, if a student is in an accident that prevents the student from returning to school, the date of the accident would be the logical withdrawal date.  However, if the student returned to school after the accident and later withdrew due to complications from the accident, the last day the student attended would be a more logical withdrawal date. 
  
  When a student dies, and the student has already begun the official withdrawal process or expressed intent to withdraw, the withdrawal date remains the date the student initiated the withdrawal process. Likewise, if the student has already been identified as a no notification withdrawal, the withdrawal date would be the date determined through that process. If the withdrawal process has not already started, the withdrawal date is the date related to the circumstance that caused the student to stop attending. For example, if the student was in an accident that prevented the student from returning to school and the student died from the injuries sustained in the accident, the date of withdrawal would be the date of the accident. In any event, the date of withdrawal must be no later than the date the student died. The University must retain documentation of the notification of the student’s death and an explanation of how the date of withdrawal was determined.
  
  When a student is administratively withdrawn by the University for conduct, outstanding bills or other reasons, the date of the withdrawal cannot be any later than the day the school terminates the student’s enrollment.  There are two additional caveats that must be considered when the school administratively withdraws a student

  • The University cannot purposely hold off on administratively withdrawing a student until after the mid-point of the period or until after the last day to receive a refund or last day to return Title IV funds. The date of the administrative withdrawal must make sense in relation to the event that caused the student to be withdrawn.  For example, if the student is withdrawn for conduct, the date could coincide with the date of the conduct hearing that suspended the student.
     
  • If students are administratively withdrawn because all of the student’s professors report that the student has not attended since a certain date, the last possible date of the withdrawal is the last date that the student was reported to have attended.
     

The date that the institution determined that the student has withdrawn is the date the University became aware that the student has ceased attending.

• Last Date at an Academically-Related Activity
  With all withdrawal types, the withdrawal date may be the student’s last date of participation in an academically related activity.
  
  Academically related activities include;
  • Attending class where there is the opportunity for direct interaction between the instructor and students
  • Submitting an academic assignment
  • Taking an exam, completing an interactive tutorial, or participating in computer-assisted instruction
  • Attending an assigned study group
  • Participating in on online discussion about an academic topic
  • Initiating contact with an instructor/faculty member to ask a question about an academic subject studied in the course.
    
    Academically related activities do not include living in the residence halls, using the school’s meal plan, participating in counseling or advising, using the campus rec center or other facilities, attending a campus event that was not part of an academic assignment, or logging into an online class without actively participating.
    
    When the last date at an academically related activity is used, documentation to support the date must be retained in the student’s file. Examples of documentation include an email from a professor advising of the last date the student was in class or something from the University’s IT department documenting the last date a student took an online exam. The student is not allowed to self-certify the last day they participated in an academically-related activity.

There are special rules that apply when a student withdraws after rescinding their original withdrawal.

If a student initiates the withdrawal process and then changes their mind, school can allow the student to rescind the withdrawal as long as the school obtains a written statement from the student stating their intent to remain in academic attendance through the end of the term/semester. Students contact the Registrar’s Office to rescind a withdrawal.

If a student subsequently withdraws after rescinding a withdrawal, the date of withdrawal is backdated to the date the student initially withdrew.

In these situations the date that the institution determined that the student withdrew would be the date the school becomes aware that the student did not or will not complete the term.

In all cases, the student’s withdrawal date must be documented in the student’s file.

Please note that when a student is owed a credit balance from Title IV Funds, the University normally has 14 days to make the refund to the student. When a student who withdraws is owed a credit balance, the University must perform the Return of Title IV Funds Calculation before a credit balance can be refunded to the student. Consequently, the school has 14 days from the date of the calculation to refund a credit-balance to the student. The Cashier’s Office is responsible for halting any credit balance when a student withdraws.

The Return of Title IV Funds Calculation (calculation) is performed in the Financial Aid Office by a designated individual or back-up. The calculation is performed using the U.S. Department of Education’s web-based application found on its Common Origination and Disbursement System.  A copy of the completed calculation worksheet is maintained in the student’s file.

The calculation is triggered when the Financial Aid Office is notified that a student has withdrawn. With the exception of Unofficial Withdrawals and withdrawals for students who did not initiate the withdrawal process but were deemed a withdrawal due to dropping modular courses, the withdrawal process starts in the Registrar’s Office.

The Registrar’s Office routes withdrawals to the Financial Aid Office when they are done with their processing. To ensure that the Financial Aid Office is aware of pending withdrawals and is able to complete them within 45 days, the Financial Aid Office receives an email notification when the withdrawal form is initiated. The Financial Aid Office also has access to a report that lists all pending withdrawals including Petitions to Withdraw.

The Registrar’s and Financial Aid Offices communicate regularly to coordinate withdrawal processing, and the Registrar’s Office is aware of the timeframes that must be met for Return of Title IV processing. Ideally, the Registrar’s Office completes withdrawal processing and routes the withdrawal to the Financial Aid Office with sufficient time to meet the deadlines. However, the email notification when the process is initiated and the online report of all pending withdrawals have been added so the Financial Aid Office can regularly check pending withdrawals and act on those that have not been officially routed. The financial aid administrator who processes Return of Title IV Funds is responsible or reviewing the outstanding withdrawals and making sure that they are processed timely.

Timely notification of withdrawals to the Financial Aid Office is important not only to ensure that Return of Title IV Funds calculations are completed timely but also to ensure that financial aid is not disbursed to students who have withdrawn. In order to be considered administratively capable, the University is required to have a process in place that immediately notifies the individuals at the University who are responsible for disbursing financial aid so they can ensure that aid is not routinely disbursed to students who have withdrawn.

During the summer term, most students attend modular courses. If a student drops some but not all of their modular courses, the student may be considered a withdrawal for Return of Title IV purposes, but not for the University Refund or Withdrawal process. To identify these types of withdrawals, the Financial Aid Office regularly runs a report to identify students who have dropped courses. The financial aid administrator who processes Return of Title IV Funds is responsible for identifying students who have withdrawn by dropping some but not all courses.

Unofficial withdrawals are generally identified at the end of the term when the Financial Aid Office runs a report to identify students who received all F grades for the term and then researches to determine if students earned their Fs by attending through the end of the term or stopped attending before the end of the term.

For both Unofficial Withdrawals and withdrawals from modular courses where students are considered withdrawal for the Return of Title IV Funds process but have not initiated the withdrawal with the Registrar’s Office, the Financial Aid Office must notify the Registrar’s Office of the withdrawal date, so the date can be reported to Clearinghouse and the National Student Loan Data System.

Since the University operates with standard terms, withdrawals are processed using payment periods.

University students are billed by term. When a student withdraws, the student’s account may reflect charges for the current term as well as prior and subsequent terms. The Return of Title IV Funds calculations must include only those charges that are for the term from which the student is withdrawing.

Only institutional charges may be included in the calculation. Institutional charges are usually the charges that were initially assessed for the semester or term, however, they may be reduced or increased by charges that were made prior to the withdrawal. For example, if a student was initially billed for 12 credits but then added 3 additional credits after the start of the term, the charges for the 15 credits could be included. If at the time of the withdrawal or afterward, the University decides to return all or a portion of the charges, that reduction in charges does not impact the charges used in the calculation. Additionally, if non-Title IV aid was used to cover institutional charges, those charges should still be included in the calculation.

Institutional charges include:

• All charges for tuition and fees but not application fees
• All charges for housing and board if contracted with the school
• Expenses for required course materials such as books, supplies, tools that the student does not have a real and reasonable opportunity to purchase outside of the school or that the University can provide to students at a rate below market value when the student’s have the option to opt out of the charges.

Charges for tuition, lab fees, meal plans and university housing are examples of institutional charges.

Non-institutional charges include:

• Charges for books, supplies and materials that the school can document can be purchased elsewhere unless University can provide to students at a rate below market value when the students’ have the option to opt out of the charges.
• Charges for group health insurance fees if the insurance is required for all students and the coverage remains in effect for the entire period charged even if the student withdraws
• Discretionary charges for things such as parking, library fines, and other discretionary charges.

Non-institutional fees would include things like bookstore charges, the cost of a parking permit, and fees that are assessed for damage to residence hall rooms.

The calculation uses the percentage of scheduled days that occurred prior to the withdrawal to determine the percentage of aid that a student has earned for the period of enrollment. Once a student has completed more than 60 percent of the days they were scheduled to complete, the student has earned 100 percent of their Title IV aid.

For standard withdrawals, the scheduled number of days will include the number of days in the term/semester minus any scheduled breaks of 5 or more days. For example, during the fall term, students usually receive a five-day break for Thanksgiving that includes Wednesday, Thursday, Friday, Saturday, and Sunday. These five days would be excluded from the number of scheduled days in the term when setting up the parameters on the calculation.

For modular withdrawals, the number of days the student was scheduled to attend will vary by student depending on the modules the student was scheduled to attend in that term. This is different from the number of countable days the student attended as articulated in the withdrawal exemptions for modular withdrawals outlined in Section 13.1 which include the countable days in the term.

For modular withdrawals, the number of scheduled days includes the number of days in the modules the student was scheduled to attend minus any breaks of five or more days. Start counting on the first day of the first module and continue counting all days except for breaks of 5 days or more through the end of the last scheduled module. Breaks of less than 5 days between modules would be counted as scheduled days for the calculation but not as countable days when determining the exemptions (see above).

Federal guidelines allow two options when determining which modules to include in the scheduled days for modular withdrawals

1. The first option allows a school to have one or more Return of Title IV Funds Freeze Dates (RFDs) in the term. For students who withdraw during the term, include modules the student was enrolled in on the RFD and the modules the student attended at least one day.

   Schools may have multiple RFDs.

   Schools must establish the RFD on a date that reflects the date when most students would have completed the registration process for the term. There must be a basis in those registration practices for the date. It cannot be a date that is deemed the most convenient for processing.

2. If the school does not use an RFD, then modules are counted in the scheduled days if
   1. The student received only Pell, IASG, and/or TEACH for the term, and the student attended at least one day in the module
   2. The student received Direct Loans or SEOG and the student attended at least one day in the module, was enrolled in the module on the first day of the period of enrollment or any time during the period of enrollment.

Currently, SDSU has not established an RFD for the summer modular terms, and operates using the second method listed above. The guidance related to RFDs was still being clarified when this policy was written.

The calculation must include both the amount of Title IV aid that was disbursed and Title IV aid that could have been disbursed for the period of enrollment from which the student withdraws. The financial aid administrator who performs the Return of Title IV Funds calculation must determine which aid should be counted as disbursed and which should count as aid that could have been disbursed in the calculation.

With the exception of inadvertent overpayments, disbursed aid includes aid that has been credited to the student’s account through the disbursement process in Banner as of the date the institution determined that the student withdrew. Any aid that was disbursed after the student stopped attending but before the date the institution determined the student withdrew is an inadvertent overpayment and is counted as aid that could have been disbursed.

Aid that could have been disbursed includes both

• inadvertent overpayments and
• other undisbursed Title IV aid where the conditions for late disbursement were met prior to the date the student became ineligible.

A student becomes ineligible on the date that

• for Direct Loans, the student is no longer enrolled in a half-time load for the period of enrollment the loan was intended for, or
• for the Title IV Grant programs, the student is no longer enrolled at the school for the award year.

Those conditions that must be met prior to the date the student became ineligible include:

• An ISIR with on official EFC has been processed by the Department.
• For SEOG, the award was made to the student in Banner
• For Direct loans the loan was originated in the Student Information System. In Banner this means that a RLADLOR record was created to originate the loan.
• For TEACH, the award was made to the student in Banner.
• For Title IV aid that requires a promissory note, the promissory note must be signed before the school performs the Return of Title IV Funds calculation.

Pell disbursements that would put a student over the Pell LEU cannot be included as aid that could have been disbursed. Additionally, if a student has an outstanding SAR Comment Code that must be resolved before awarding, that issue must be resolved before the calculation in order for it to be included as aid that could have been disbursed.

Aid that could have been disbursed is not always disbursable to a student. This includes inadvertent overpayments that may have already been disbursed to a student. While inadvertent overpayments are included as aid that could have been disbursed, if the disbursements do not meet the criteria for late disbursement, then the entire disbursement will need to be unpaid. If the aid that was inadvertently overpaid does meet the criteria for late disbursement, only the portion that was not “earned” per the calculation will need to be returned. Returning the funds must be done within 45 days of the date of the institution’s date of determination of withdrawal.

If a student is selected for Verification and the student provides the required documentation after withdrawing but before the Verification submission deadline, and before the 30-day calculation deadline, the calculation includes all Title IV aid for which the student established eligibility as a result of Verification and for which the conditions of late disbursement were met prior to the loss of eligibility due to withdrawal. Generally, SDSU does not award financial aid prior to completion of Verification, so it would be unlikely that a student would have met the requirements to receive a late disbursement of a Direct Loan in this way. The Grant amounts included in the calculation would be based on the EFC after Verification.

If a student who is selected for Verification does not complete the Verification process, only PLUS Loans and Direct Unsubsidized Loans that meet the conditions of late disbursement should be included in the calculation as they are not subject to Verification.

See section 13.4 for a discussion of SDSU’s policy related to Post-Withdrawal Disbursements.

When a student received less Title IV Aid than the student earned (as determined by the Return of Title IV Funds Calculation), a post-withdrawal disbursement must be made. Post-withdrawal disbursements must meet the conditions for late disbursement (see discussion in 13.3)

The financial aid administrator who performs the Return of Title IV Funds calculation is responsible for identifying when a post withdrawal disbursement should be offered to a withdrawn student or parent borrower. The calculation worksheet will indicate if a post-withdrawal disbursement is due. Keep in mind that a student who withdrew after the 60 percent point and has earned all of their aid for the term, may qualify for a post-withdrawal disbursement.

The amount of the post withdrawal disbursements that can be offered/disbursed is determined by the earned aid in the calculation and not the student’s charges.

Post-withdrawal disbursements must be disbursed within 180 days of the date of determination except where otherwise noted. In accordance with cash management, funds must be credited to the student’s account within 3 days of receiving the funds.

Post-withdrawal disbursements of any Title IV Funds cannot be made to a student who has died.

When a student is owed a post-withdrawal disbursement, the disbursement should be made from grant funds before loan funds. For example, if the Return of Title IV Funds Calculations indicates that the student has $1000 in aid that could have been disbursed that was earned, and the student meets the requirements for late disbursement, available grant funds must be used to cover the $1000 before loan funds. Only if the student does not have $1000 in grant eligibility would loans be offered as a post-withdrawal disbursement.

If a student or parent in the case of a PLUS Loan qualifies for a post-withdrawal loan disbursement, the Financial Aid Office must offer that disbursement to the student or parent within 30 days of the date of the school’s determination that the student withdrew. The financial aid administrator who processes the Return of Title IV Funds is responsible for notifying students and parents of post-withdrawal disbursement loan eligibility, tracking the responses, and meeting all required deadlines.

The notice to the student or Parent PLUS Loan borrower must

• Identify the type and amount of the loan funds to be disbursed to credit the student’s account and/or to refund to the student
• Explain that all or a portion of the funds can be accepted or declined
• Explain how to accept or decline the funds
• Explain the obligation to repay the funds regardless of whether or not they are posted to the student’s account or disbursed directly to the student or parent
• Explain that the student or parent borrower cannot receive a direct disbursement of loan funds that the University is using to credit the student’s account and cover outstanding eligible charges.
• Provide the deadline for accepting the funds
• Clarify that if funds are not accepted by the deadline, the school is not required to make the disbursement.

For loan funds, the student or parent borrower must confirm that they want the funds before the funds can be disbursed. Confirmation may include a student accepting the funds on the Financial Aid Self Service portal or providing written confirmation including a signed statement or an email from the student’s Jack’s email account. Parent borrowers can confirm by providing signed written confirmation including a signed statement or an email from the email listed on the PLUS Loan application.

The University may set a deadline for accepting funds, but students and parents must be allowed a minimum of 14 days to accept the funds. SDSU allows 45 calendar days for post-withdrawal disbursements to be accepted.

At the discretion of the financial aid administrator who processes the Return of Title IV Funds, the University may honor a request for a post-withdrawal disbursement that is received after day 45. For example, if the Return of Title IV Funds Calculation is completed before the University refund policy is implemented and the student does not know how much will be owed to the University until several weeks after the Post-Withdrawal Disbursement is offered, the Financial Aid Office may choose to allow the student or parent to accept funds after day 45. However, if a late request to disburse funds is honored, the Financial Aid Office must disburse all of the funds requested and not just those that cover the student’s bill.

Additionally, if a late request for a post-withdrawal disbursement of loan funds is not granted, the financial aid administrator responsible for the Return of Title IV Funds Calculation must notify the student or parent borrower in writing that the disbursements will not be made and provide an explanation of why they won’t be made.

Copies of all post-withdrawal notifications and response from students and parents must be retained in the students file along with documentation of the outcome.

Post-withdrawal loan disbursements must be made within 180 days of the date of withdrawal determination.

Students do not need to confirm acceptance of post-withdrawal disbursements of grant funds. While any grant funds that are used to pay outstanding charges owed to the school must be made within 180 days, those owed to the student as a refund must be disbursed as soon as possible but not later than 45 days of the date of determination of withdrawal.

SDSU cannot delay paying the grant funds, but it may advise students of the advantage to turning down grant funds to preserve future eligibility. Additionally, if a student contacts SDSU to turn down the grant funds, the disbursements should be canceled. The contact should be in writing by signed statement or email from the Jack’s email account.

Disbursements and Refunds

Post withdrawal disbursements can be applied to outstanding institutional charges for the term the disbursements were intended and other educational charges for the same term if the student has authorized Title IV funds to pay non-institutional charges.

If a refund is due after a post-withdrawal disbursement, it must be made within 14 days of disbursement and the recipient cannot be required to pick up the disbursements at the school. SDSU’s disbursement process allows for refunds to be received by paper check that is mailed to the student/parent or direct deposit into a bank account.

The information provided in the notice must include the type and amount of the loan funds, that the loan funds must be repaid, and explain that the student or parent (for PLUS) may accept or decline all or a portion of the funds. It should also include information (such as the amount the student owes to the University) needed for the student to make an informed decision about whether or not to accept the funds and let the student or parent know that the University will retain any portion of the funds needed to cover any eligible outstanding charges owed to the University. The student or parent must given at least 14 days to respond to the notice, and all post-withdrawal disbursements must be made within 180 days of the date the University determined that the student withdrew.

The Return of Title IV Funds Calculation determines how much financial aid the student has earned and how much is “unearned”. Unearned financial aid that has been disbursed must be returned to the Title IV Programs as soon as possible but no later than 45 days of the date the institution determined that the student withdrew. The financial aid administrator who performs the calculation is responsible for ensuring that unearned aid is undisbursed from the student’s account within a timeframe that will allow the Cashier’s Office to return the funds to the appropriate Federal Programs by day 45.

Generally, students who attend past the 60 percent point in the term have earned all of their funds and don’t have to have any funds returned.

The Federal Regulations stipulate the order in which funds must be returned. The order from first to last is:

• Direct Unsubsidized Loans (excluding Direct PLUS Loans)
• Direct Subsidized Loans
• Direct Parent PLUS Loans and Graduate Plus Loans
• Federal Pell Grants
• Federal Supplemental Educational Opportunity Grants (SEOG)
• TEACH Grants

The calculation first determines how much of the unearned funds are owed back by the school, and then how much of the unearned funds must be returned by the student. The calculation output will delineate these amounts. The amounts will depend on how much of the earned aid was used to cover institutional charges.

The University must return the amounts of grant funds and loan funds that the calculation determines are owed by the University.

The unearned loan funds that the student is responsible to repay may be repaid according to the terms of the promissory note, so students do not have to immediately repay loan funds that were unearned. The school must repay the loan funds the school is required to return.

For any Title IV Grant Funds where the student is required to return $50 or less, the funds do not have to be returned. If the calculation indicates that the student is responsible for returning unearned grant funds of more than $50, the University will return these funds on behalf of the student. Generally, this will create a balance on the student’s account that the student owes to SDSU. This prevents SDSU from having to report the student as having a grant overpayment to NSLDS and any default referrals if the student does not repay timely.

The Financial Aid Office is responsible for initiating the return of funds process. To do this, the student’s financial aid is reduced in the Banner Financial Aid system to reflect the earned financial aid, and the disbursement process for the term is run to “unpay” the funds from the student account. As the funds unpay from the student’s account, the transaction shows up in the Banner Finance System as funds that have been returned to the accounts that are used for the funds that were unpaid. The Grant’s Office is responsible for ensuring that the funds are held in the University’s federal funds bank account and for returning any unused funds to G5 as required by cash management rules.

Any funds that are unpaid must be reported to the Common Origination and Disbursement System (COD). SDSU exports records to COD daily, and the reduced awards should be reported to COD the same or subsequent day. This will in turn update the student’s loan obligations to reflect new balances and grant usage for Pell, IASG, and TEACH.

Within 14 days of returning funds as the result of a withdrawal, the Financial Aid Office provides a written correspondence to each student for whom funds were unpaid. The correspondence advises the students of the types and amounts of funds that were returned.