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Return of Title IV Funds

The Higher Education Amendments of 1998, Public Law 105-244 require colleges to calculate the Return of Title IV Funds Policy when a recipient of Title IV aid completely withdraws from the college through the 60 percent point during a payment period. The institution must calculate the amount(s) of Title IV aid the student earned and return the unearned portion(s) of the Title IV fund(s) to the Title IV program(s). The institution and student may be required to return unearned Title IV funds to the Title IV programs.

A student’s withdrawal date is determined:

(1)    when a student begins the institution’s withdrawal process; or notifies the institution of their intent to withdraw, is the last date of academic attendance as determined by the school from its attendance records in class(es).

(2)    when a student is unofficially withdrawn by instruction, the last date of academic attendance is determined by the attendance records in class(es).

Under the new regulations effective July 1, 2021, for all programs offered in modules, a student is considered withdrawn for Title IV purposes if the student ceases attendance and is not scheduled to begin another course within a payment period or period of enrollment for more than 45 calendar days after the end of the module the student ceased attending, unless the school obtains written confirmation from the student that he or she will attend a later module in the same payment period or period of enrollment. If a school obtains a written confirmation of future attendance but the student does not return as scheduled, the student is considered to have withdrawn.

In addition, a student is not considered to have withdrawn, if the student successfully completes:

(1) All requirements for graduation from his or her program before completing the days or hours in the period that the student was scheduled to complete

(2) One module that includes 49% or more of the number of days in the payment period

(3) A combination of modules that when combined contain 49% or more of the number of days in the payment period; or

(4) Coursework equal to or greater than the coursework required for the institution’s definition of a half-time student.

The Financial Aid Office determines if the student was a recipient of Title IV funds who withdrew prior to the 60 percent point and performs the Return of Tile IV Funds calculation. Under this policy, the school determines the amount of Title IV funds a student has earned and returns the unearned portion. The Financial Aid Office sends written notification to the student informing the student of the amount owed no later than thirty calendar days after the date of the school’s determination that the student withdrew. The school must return any unearned Title IV funds it is responsible for within 45 days of the date the school determined the student withdrew.

If the Return of Title IV funds calculation determines the student received less Title IV funds than the amount earned, the institution must make a post-withdrawal disbursement to the student of the earned aid that was not received within 180 days of the date the institution determines the student withdrew. In order to make a post-withdrawal disbursement, the school must have a processed Institutional Student Information Record (ISIR) with an official Expected Family Contribution (EFC). To be eligible for a post-withdrawal disbursement, the student must also meet all Federal Guidelines outlined by the Department of Education. For a student who withdraws after the 60% point in time, a R2T4 calculation will be performed to determine whether the student is eligible for a post-withdrawal disbursement.

A school must return Title IV funds to the programs from which the student received aid, in the following order:



If applicable, funds must also be returned to the State Grant Funds.

NOTE: The Return to Title IV Funds policy is separate from Mitchell Community College’s institutional refund policy.