As an example, consider a student who enrolls in two eight-week modules within a payment period. The student is awarded Pell Grant and Direct Loans, but due to administrative delays the institution is unable to make the Title IV disbursements while the student is still in attendance. The student successfully completes the first module and meets the conditions for a withdrawal exemption. The student then begins the second module, but ceases attendance prior to receiving any Title IV disbursements for the period.
The student is considered a completer and, for Title IV purposes, remains enrolled throughout the entire payment period. The student qualifies for a Pell Grant disbursement at half-time enrollment status because the student was enrolled half-time on the Pell recalculation date and the student began attendance in coursework sufficient to comprise half-time enrollment. For Direct Loan purposes, the student was enrolled half-time and had begun attendance in coursework that comprised half-time enrollment at the time the student ceased attendance.
Therefore, the institution must disburse the Direct Loan funds for which the student is eligible during the payment period. This scenario would change significantly if, after completing the first module, the student never began attendance in the second module.
In that case, since the student never began attendance in coursework sufficient for half-time enrollment, the student would be subject to a mandatory Pell Grant recalculation and would only qualify for a less-than-half-time Pell Grant disbursement. In this circumstance, the student would also be ineligible to receive Direct Loan funds for the period because the student never commenced attendance in coursework comprising half-time enrollment.
MOD-Q Our institution has three summer periods in which students can enroll in coursework and those sessions are combined into a single summer term for the purposes of awarding Title IV funds. Is our summer term considered to be offered in modules? MOD-A Yes. If an institution combines multiple summer sessions into a single term for Title IV purposes, and none of those sessions span the entire term, each of the summer sessions is considered a module and a student enrolling in any one of those session is treated as being enrolled in a program offered in modules for that term.
Does this day rule for determining a withdrawal apply to all institutions that fall under the definition of an institution that is required to take attendance i. How does the day rule apply when a student is not treated as a withdrawal from a program offered in modules because he or she has confirmed attendance in a module that begins later in the payment period or period of enrollment? TA-A1: The day rule applies to all institutions that are required to take attendance.
Institutions that are required to take attendance are expected to have a procedure in place for routinely monitoring attendance records to determine in a timely manner when a student withdraws. For example, a student enrolls at an institution that is required to take attendance for one course in each of three modules. The student completes the first module, but ceases attending the second module on October 4, prior to its completion.
The student provides written confirmation that he will attend the third module, scheduled to begin October 24, but does not return. In accordance with the previous guidance, if a student provides notification to the institution of his or her withdrawal prior to the date that the institution normally would determine that the student withdrew, the date of determination is the date of the student's notification.
The institution is NOT required to administratively withdraw a student who has been absent for 14 days.
However, after 14 days, it is expected to have determined whether the student intends to return to classes or to withdraw. If the student is eventually determined to be a withdrawal, the end of the day period begins the timeframe for completing a R2T4 calculation. If an institution has a policy that states the maximum number of excused absences that can occur after which a student will be administratively withdrawn, it may delay contacting the student until that date. An institution must return the amount of Title IV funds for which it is responsible as soon as possible, but no later than 45 days after it determines or should have determined that the student withdrew.
TA-Q2: If an institution monitors whether its online students log into classes, is this an institution that is required to take attendance? TA-A2: No. The monitoring of whether online students log into classes does not by itself result in an institution being an institution that is required to take attendance for Title IV, HEA program purposes because monitoring logins alone is not monitoring academic engagement as defined under 34 CFR TA-A3: Yes.
Take, for example, a student who is not in attendance in his or her classes on the last day of a two-week period of required attendance taking. TA-A4: No. Only if the institution requires its faculty to collect or record information about whether a student was in attendance is it considered to be one that is required to take attendance. TA-Q5: If an institution requires its faculty to take attendance for some courses in a program, but not others for example, all core courses, but not elective courses , is this an institution that is required to take attendance?
TA-A5: An institution is only required to take attendance if attendance taking is required in all classes in the program for a period of time. If, for example, an institution requires that attendance be taken in all core courses, but not elective courses, and the core and elective courses are always taken together throughout a payment period, then the institution would not be classified as being required to take attendance for that program because attendance taking is not required for all courses for any period of time.
However, if the core courses in the program are taken together in isolation—for example, over the first five weeks of a payment period—then this would be a program for which the institution is required to take attendance for those first five weeks because, for that period of time, attendance is required in all courses.
TA-Q6: Please confirm that an institution is not an institution that is required to take attendance if it has a census that reviews which students academically attended during a defined preceding period--e. TA-A6: Section So, if the institution is taking attendance on just the 14th day, it is not an institution that is required to take attendance for Title IV, HEA program purposes.
Also, if the institution is taking attendance to determine whether each student attended at least once during the period, but is not continuing to monitor attendance for a student subsequent to the one day of attendance, it is not an institution that is required to take attendance for Title IV, HEA program purposes. TA-Q7: For a program that is offered in modules, may the institution require that attendance be taken on only one specified day for each module i.
TA-Q8: If faculty at an institution are required to take attendance and some faculty do not comply with the requirement, how should the institution determine a withdrawal date for a student who withdraws?
The institution is responsible for ensuring that it is in compliance with the requirement to take attendance. TA-Q One of our students completed an online orientation prior to the start of a term, but we have no record of academic engagement after the term started. If a period of orientation takes place prior to the start of a course, it would not qualify as attendance in an academically related activity.
Additionally, an orientation may or may not be considered academic engagement depending on the types of activities that are involved in the orientation. Institutions should make clear what will and will not be considered academic engagement in their policies and procedures and apply those policies and procedures consistently to all students.
If so, what should the institution use as the effective date of the withdrawal? ER-A1: There are occasions when a student is considered withdrawn for enrollment reporting purposes but no R2T4 calculation has to be performed such as when a student completes a term but does not return for a subsequent term.
If the student is not treated as a withdrawal and there is no R2T4 calculation, then the institution does not have to use the R2T4 process to determine the effective date of the withdrawal for NSLDS enrollment reporting purposes. This guidance remains in effect under the Distance Education and Innovation regulations effective July 1, , which treat students as having completed a term when they meet the conditions for an exemption from treatment as a withdrawal. Therefore, when a student is treated as having completed a term e.
Conversely, if the student is treated as a withdrawal and the R2T4 requirements apply, the institution must report the student as withdrawn with an effective date as determined under 34 CFR Therefore, when a student graduates during a term upon completion of a module with an end date that occurs prior to the end date of the term, the institution should use the effective date that it assigns for graduation.
GI-A1: No. To qualify for a withdrawal exemption for successfully completing a module that comprises at least 49 percent of the days in a payment period excluding scheduled breaks of five or more consecutive days and all days between modules , a student would need to earn a passing grade in at least one course offered in that module. Similarly, to be considered to have completed a combination of modules that comprises at least 49 percent of the days in the payment period excluding scheduled breaks of five or more consecutive days and all days between modules , the student must have earned a passing grade in at least one course in each of the modules that were used to calculate whether the student met the conditions for the exemption.
GI-A2: Yes. However, if we determine they completed the full semester, would we be required to treat the student as withdrawn and complete an R2T4 calculation? Can we treat this student as having completed the payment period, or do we need to perform an R2T4 calculation?
Students are usually expected to complete the required work within a reasonable time to receive credit and a passing grade. In general, an institution must perform an R2T4 calculation for a student within the required timeframe unless it has evidence that the student completed the payment period or period of enrollment.
An institution can document that a student has completed a payment period or period of enrollment if the student has received a passing grade in the last course or courses that the student was scheduled to attend for that period.
However, if a student does not have passing grades and an institution has no other evidence that the student completed the period, the student must be treated as a withdrawal unless the student is on an approved leave of absence.
A term-based, credit-hour institution that wishes to explore the possibility of granting an LOA that meets the criteria specified in 34 CFR WI-Q1: Do the withdrawal exemption regulations apply to both undergraduate and graduate students and programs?
WI-A1: Yes. The exemptions apply to all students who withdraw, regardless of program level or graduate or undergraduate status. WI-Q2: A term is broken into four consecutive five-week modules, each of which constitutes 25 percent of the payment period. If a student successfully completes only the first and last modules, would the student be exempt from the R2T4 calculation even though the modules that the student completed did not occur consecutively?
WI-A2: In a program offered in modules, a student is not considered to have withdrawn if the student successfully completes a combination of modules that, when combined, include 49 percent or more of the number of days in the payment period, excluding scheduled breaks of five or more consecutive days and all days between modules. WI-Q3: How does an institution establish the denominator for the calculation to determine whether a student has successfully completed at least 49 percent of a payment period or period of enrollment?
Does the institution use the same method for determining the denominator as the R2T4 calculation itself? WI-A3: The method for determining the denominator for the withdrawal exemption differs from the method for determining the denominator for the R2T4 calculation itself. To determine the denominator of the calculation for whether a student has successfully completed at least 49 percent of a payment period or period of enrollment, an institution performs three steps.
The institution—. The number of days in the term for purposes of the withdrawal exemption will be the same for all students who enrolled in that term. Only the numerator of the withdrawal exemption calculation — the number of days in modules that the student successfully completed — may differ for each student.
For example, consider a term that is comprised of two modules, each of which is 48 days in length. There are no scheduled breaks of more than five consecutive days during the semester but there is a four-day break between the two modules.
The institution begins by adding all the days between the start and end date of the regular term days and then subtracting the number of days between the modules in the term four days. The total number of days in the denominator of the withdrawal exemption calculation for this term is therefore 96 days.
A student enrolls during this term in one three-credit day course and one three-credit, day course in the first module. There are no scheduled breaks of five or more consecutive days during the semester but there is a four-day break between modules. The student successfully completes the first module and subsequently completely withdraws from the day course.
This process is different from the process to determine the denominator in the R2T4 calculation itself. The denominator of the R2T4 calculation includes days between modules if there are fewer than five consecutive days between modules. WI-Q4: When a student enrolls in an intersession that is connected to another term e. Are intersessions included in the denominator for the withdrawal exemption calculation in the same manner?
WI-A4: No. As explained in WI-A3, the denominator of the withdrawal exemption calculation is the same for all students who enroll in a given term. By definition, an intersession is attached to a term and is not part of the regular term. Therefore, the days in an intersession are always excluded from the denominator of the withdrawal exemption calculation.
Similarly, any other days that occur outside the regular term dates e. For example, consider an intersession that is 40 days in length and a regular Spring term to which it is attached that includes 80 days with no scheduled breaks. A student is scheduled to attend one full-term course during the regular Spring term and one course during the intersession. The student successfully completes the intersession course, but does not attend the full-term course that the student was scheduled to attend.
The denominator of the withdrawal exemption calculation includes the 80 days in the regular term and ignores the days in the intersession. Therefore, because the student successfully completed the intersession course, which included 40 days 50 percent of the number of days in the regular term , the student is treated as having completed a module comprising at least 49 percent of the days in the regular term. This student qualifies for a withdrawal exemption and no R2T4 calculation is required.
WI-Q5: A student withdraws from a degree program in the middle of a payment period, but graduates from a shorter certificate program unaffiliated with the program in which the student is enrolled as a regular student at that time based on coursework that was completed at the time the student withdrew.
Would the withdrawal exemption for graduation or completion of requirements for graduation apply to this student? WI-A5: No. The regulations for the graduation withdrawal exemption were intended to apply only to graduation from the program in which the student was enrolled as a regular student and for which the student was receiving Title IV aid for the payment period in question.
The exemption does not apply when a student graduates or receives a credential for another program. WI-Q6: An institution only offers classes that span the length of a payment period and a single module that begins at the start of the period and ends in the middle of the period. WI-A6: No. The denominator of the withdrawal exemption calculation would include all days in the normal term excluding any scheduled breaks of at least five consecutive days.
WI-Q7: We have modules of various lengths and some overlap. We only have breaks between certain modules, but some breaks are not common to all modules. When counting days in the modules to determine if the student meets the conditions for a withdrawal exemption for successful completion of a module or modules that comprise at least 49 percent of the payment period, do we include all breaks or only breaks that are common to all modules during the payment period?
WI-A7: For purposes of performing the calculation to determine whether the student meets the conditions for a withdrawal exemption for successful completion of at least 49 percent of the payment period, a day is included in the numerator if that day was included in at least one module or full-term course that the student successfully completed and is not part of a break of at least five consecutive days during which no coursework was taking place.
The process for determining the number of days in the denominator of this calculation is described in WI-A3. For either the numerator or denominator, if a day is included in multiple overlapping modules, the day is only counted once. For example, if the payment period includes four modules and there is a three-day break between each module, then the institution would subtract nine total break days between modules from the total number of days in the payment period.
However, if the four modules overlapped one another and there were not any breaks between modules, the institution would not subtract any break days between modules from the denominator of the withdrawal exemption calculation. WI-Q8: An institution offers both modules and courses that span the entire payment period. The full-term courses have a scheduled break of at least five consecutive days, but there is no scheduled break in the modules as there is in the full-term courses.
Should we exclude the scheduled break in the full-term course from the denominator of the withdrawal exemption calculation? WI-A8: No. If a scheduled break applies to some courses in the term, but not others, it is not excluded from the denominator of the withdrawal exemption calculation. However, when determining the numerator of the withdrawal exemption calculation, the institution must exclude scheduled breaks of at least five consecutive days in each module that the student successfully completed regardless of whether those scheduled breaks apply to other courses in the term.
Note that the process for establishing the denominator of the withdrawal exemption calculation differs from the treatment of scheduled breaks for purposes of the R2T4 calculation itself.
CHP-Q1: Our State permits students to graduate prior to completing all of the clock hours normally established in a program if the students can demonstrate that they have mastered all the skills in the program. The student graduated having successfully completed only clock hours. Given to the changes to the regulations effective July 1, , is this student exempt from the R2T4 requirements? CHP-A1: Yes. Although the student did not successfully complete all the clock hours in the program, they are not treated as a withdrawal and the institution is not required to perform an R2T4 calculation because the student graduated from the program.
However, allowing a student to graduate before successfully completing the hours in the program could still require the institution to return Title IV funds for the student. Then, if the institution had disbursed Title IV aid in an amount greater than the amount that it recalculates, the institution must return the difference between the recalculated amount of Title IV for which the student was eligible based on enrollment in the shorter program and the amount that was disbursed.
The institution, not the student, is ultimately responsible for returning the Title IV aid in these situations. This is because, as explained in CHP-A2, the Department expects that students will progress individually through clock hour programs and not all students will successfully complete all of the hours in a program at the same time.
The Department treats a situation when a student graduates before successfully completing the hours in a clock hour program as a situation where the student had graduated from a shorter program, and therefore was never eligible for the additional funds, including when the original disbursements were made. CHP-Q2: If a student enrolled in a clock hour program successfully completes all of the clock hours in the final payment period, but does so before completing all of the instructional weeks scheduled in the payment period, would that also require re-proration?
CHP-A2: No. If a student successfully completes all clock hours in a program prior to the normal number of weeks elapsing, the student is not considered a withdrawn student and no proration of Title IV aid received has to occur.
Students progress individually through clock hour programs. Therefore, it is not uncommon for some students to complete a program somewhat earlier or later than the reported weeks. However, the number of clock hours that make up a program of study are the same for all students. As a reminder, if a student successfully completes all of the hours in the program before completing a sufficient number of weeks of instruction to enter the final payment period, the student will not qualify for any Title IV disbursements for that final payment period.
CHP-Q3: How should an institution treat hours of excused absences when a student is permitted to graduate before successfully completing all of the clock hours in a program? CHP-Q4: In some situations, students will be permitted to graduate before successfully completing all of the clock hours in the program after the point at which the student was scheduled to complete at least 60 percent of the payment period or period of enrollment.
In these situations, can the institution choose not to apply the R2T4 exemption and perform the R2T4 calculation instead? CHP-A4: No. The regulations at 34 CFR An institution may not apply the R2T4 requirements to a student who, under the regulations, is not considered to be a withdrawn student for Title IV purposes.
SD-Q1: A student enrolls in two day modules in a term, but does not enroll in any full-term courses. The student completes but fails the first module, then begins attendance in the second module, but subsequently withdraws before completing it. There is a four-day break between the modules during which the student was not enrolled in any classes. Is this scheduled break included in the calculation? SD-A1: Yes. Because the student attended both modules, the days in both modules would be included in the total number of days in the payment period.
For this student, there was also a short break of four days between the two modules when the student was not enrolled in any other courses. This list is subject to change. On June 26, , the Department conducted a webinar providing background information on the Gainful Employment Informational Rates that were made public earlier that day. A copy of the slide deck in both. On October 18, , the Department published a notice in the Federal Register announcing public meeting sessions to receive oral presentations and to interact with commenters regarding comments that were submitted to the Department of Education in response to its Notice of Proposed Rulemaking on Program Integrity: Gainful Employment, published in the Federal Register on July 26, On August 11, , the Department held a conference call regarding the July 26, , Notice of Proposed Rulemaking and gainful employment.
Through this NPRM, the Secretary proposes to amend the Student Assistance General Provisions to establish measures for determining whether certain postsecondary educational programs lead to gainful employment in recognized occupations, and the conditions under which these educational programs remain eligible for the student financial assistance programs authorized under title IV of the Higher Education Act of , as amended HEA.
Issue Summaries: PDF 2. Search for:. Toggle navigation U. Student Loans Grants Laws Data. Additional resource information: To access the public comments submitted in response to the Program Integrity Notice of Proposed Rulemaking pertaining to gainful employment, go to: www. Meetings on Gainful Employment The Department hosted two days of public hearings and over 30 meetings to hear from individuals and organizations who submitted comments on the proposed regulations regarding gainful employment.
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