Return to Title IV Funds Policy (R2T4)

University of the West of Scotland (UWS) is required to complete a Return to Title IV (R2T4) calculation for students, in receipt of US Federal Loan, who withdraw from their studies during the course of the payment period. The withdrawal may be either permanent or temporary or as a result of academic failure.

A withdrawal is defined as a student formally informing the University that they intend to withdraw from their studies and follow UWS procedures for withdrawal or interruption of studies. Information regarding the processes of withdrawal from or Interruption of Studies can be found in the website at 'Things not going well?'. Students considering withdrawal or interruption of their studies are advised to contact their Personal Tutor/Programme Leader as soon as possible for advice.

A student who has withdrawn will also be expected to comply with the Student Fee and Refund Procedure (see the Finance section of the Policies, Procedures & Guidance webpage). Student fees are charged on a pro-rata basis for part-year study. Therefore the student may owe funds to UWS to cover any unpaid institutional charges.

When a student withdraws during a payment period, the amount of Title IV program assistance that has been earned up to that point is determined by a specific formula. The date of withdrawal is determined by the Personal Tutor/Programme Leader/School and will be the last day the student attended. If the student received (or the University received on the student’s behalf) less assistance than the amount that is earned, the student may be able to receive those additional funds. If the student received more assistance than was earned, the excess funds must be returned by the University and/or the student. Students who are not in attendance are notified to Student Administration by the School confirming the last date of attendance. The University will use the last date of attendance to compute the R2T4 formula.

In the case where a student notifies the Personal Tutor/Programme Director or a member of staff that he or she intends to withdraw, the student must be informed of the need to inform the School in writing, citing the reason for withdrawal in writing and the effective date. The School will forward the information to Student Administration. Should the student fail to write or there is a lag between the notification and the student’s written confirmation, the earlier date of notification will be used in calculating the R2T4 formula.
In the event a student receives all failing grades for a term, the Personal Tutor/Programme Leader will determine if the failing grades were earned or represent a lack of attendance As UWS records attendance of students, the withdrawal date will always be the date of last recorded attendance. UWS will make a determination within 14 days of the last recorded attendance whether a student will be withdrawn or remain active. Students who do not attend even one class, are ineligible for Title IV funds and all of the loan proceeds will be returned to the lender.

The amount of assistance earned is determined on a pro rata basis. The payment period is the term for which the loan was certified and the percent of attendance is calculated by dividing the number of days attended by the total number of days in the payment period. For example, if the student completes 30% of the payment period or period of enrolment, the student has earned 30% of the assistance they were originally scheduled to receive, i.e. it is considered that the disbursement has not been fully ‘earned’ and a ‘Return of the Title IV Funds’ must be carried out. Once the student has completed more than 60% of the payment period or period of enrolment, all the assistance that the student was scheduled to receive for that period is considered to have been ‘earned’. If the student did not receive all of the funds that were earned, he or she may be due a post-withdrawal disbursement. If the post-withdrawal disbursement includes loan funds, the student may choose to decline the loan funds so that additional debt is not incurred. UWS will use the R2T4 worksheets as provided by the US Department of Education to determine how much of the loan may be retained and how much must be returned.

The University may automatically use all or a portion of the post-withdrawal disbursement (including loan funds, if the student accepts them) for tuition, fees, and accommodation. For all other University charges, the University needs the student's permission to use the post-withdrawal disbursement. If the student does not give permission the student will not be offered the funds. However, it may be in the student’s best interest to allow the University to keep the funds to reduce the debt at the University.

There are some Title IV funds that students are scheduled to receive that cannot be earned once a student withdraws because of other eligibility requirements. If the student receives (or the University receives on behalf of the student) excess Title IV program funds that must be returned, the University must return a portion of the excess equal to the lesser of:

• the institutional charges multiplied by the unearned percentage of the funds
• the entire amount of excess funds

The University must return this amount even if it didn't keep this amount of the Title IV program funds. If the University is not required to return all of the excess funds, the student must return the remaining amount. Any loan funds that must be returned, the student must repay in accordance with the terms of the promissory note. That is, scheduled payments are made to the holder of the loan over a period of time. Students who have received a refund of their loan proceeds before withdrawing may be required to return part or all of those funds to the lender.

Title IV funds will be returned in the following order:

• Unsubsidised Federal Direct Loans
• Subsidised Federal Direct Loans
• PLUS Loan Funds

The requirements for Title IV program funds when students withdraw are separate from any refund policy that the University may have. Therefore, the student may still owe funds to the University to cover unpaid institutional charges. The University may also attempt to collect from the student any Title IV program funds that the University was required to return.

UWS students have the right to request to interrupt their studies for exception reasons, such as bereavement, health issues or other issues as defined in the University Regulations and the Authorised Interruption of Study - Guidance Notes (see the Student section of the Policies, Procedures & Guidance webpage). Students who elect to interrupt their studies or take a leave of absence will have the right to re-engage with their studies at the end of their interruption. However, Title IV students must be withdrawn from their loan programme should their leave of absence (and any other planned absence) exceed 180 days in any 12-month period, and would require to re-apply in order to fund their continuation of studies.

University of the West of Scotland (UWS) is required to complete a Return to Title IV (R2T4) calculation for students, in receipt of US Federal Loan, who withdraw from their studies during the course of the academic year. The withdrawal may be either permanent or temporary or as a result of academic failure.

A withdrawal is defined as a student formally informing the University that they intend to withdraw from their studies and follow UWS procedures for withdrawal or interruption of studies.  Information regarding the processes of withdrawal from or Interruption of Studies can be found on the website at 'Things not going well?' Students considering withdrawal or interruption of their studies are advised to contact their Personal Tutor/Programme Leader as soon as possible for advice.

A student who has withdrawn will also be expected to comply with the Student Fee and Refund Procedure. Student fees are charged on a pro-rata basis for part-year study. Therefore the student may owe funds to UWS to cover any unpaid institutional charges.

When a student withdraws during a payment period, the amount of Title IV program assistance that has been earned up to that point is determined by a specific formula. The date of withdrawal is determined by the Personal Tutor/Programme Leader/School and will be the last day the student attended. If the student received (or the University received on the student’s behalf) less assistance than the amount that is earned, the student may be able to receive those additional funds. If the student received more assistance than was earned, the excess funds must be returned by the University and/or the student. Students who are not in attendance are notified to Student Administration by the School confirming the last date of attendance. The University will use the last date of attendance to compute the R2T4 formula.

In the case where a student notifies the Personal Tutor/Programme Director or a member of staff that he or she intends to withdraw, the student must be informed of the need to inform the School in writing, citing the reason for withdrawal in writing and the effective date. The School will forward the information to Student Administration. Should the student fail to write or there is a lag between the notification and the student’s written confirmation, the earlier date of notification will be used in calculating the R2T4 formula.

In the event a student receives all failing grades for a term, the Personal Tutor/Programme Leader will determine if the failing grades were earned or represent a lack of attendance. In the event it is determined that those grades were the result of lack of attendance, the Personal Tutor/Programme Director will attempt to determine the last day of attendance and use that date in the R2T4 calculations. If the exact date cannot be determined, the University will assume a 50% attendance, and use that date as the last date of attendance. Students who do not attend even one class, are ineligible for Title IV funds and all of the loan proceeds will be returned to the lender.

The amount of assistance earned is determined on a pro rata basis. The payment period is the term for which the loan was certified and the percent of attendance is calculated by dividing the number of days attended by the total number of days in the payment period. For example, if the student completes 30% of the payment period or period of enrolment, the student has earned 30% of the assistance they were originally scheduled to receive, i.e. it is considered that the disbursement has not been fully ‘earned’ and a ‘Return of the Title IV Funds’ must be carried out. Once the student has completed more than 60% of the payment period or period of enrolment, all the assistance that the student was scheduled to receive for that period is considered to have been ‘earned’. If the student did not receive all of the funds that were earned, he or she may be due a post-withdrawal disbursement. If the post-withdrawal disbursement includes loan funds, the student may choose to decline the loan funds so that additional debt is not incurred. UWS will use the R2T4 worksheets as provided by the US Department of Education to determine how much of the loan may be retained and how much must be returned.

The University may automatically use all or a portion of the post-withdrawal disbursement (including loan funds, if the student accepts them) for tuition, fees, and accommodation. For all other University charges, the University needs the student's permission to use the post-withdrawal disbursement. If the student does not give permission the student will not be offered the funds. However, it may be in the student’s best interest to allow the University to keep the funds to reduce the debt at the University.

There are some Title IV funds that students are scheduled to receive that cannot be earned once a student withdraws because of other eligibility requirements. If the student receives (or the University receives on behalf of the student) excess Title IV program funds that must be returned, the University must return a portion of the excess equal to the lesser of:

• The institutional charges multiplied by the unearned percentage of the funds, or
• The entire amount of excess funds.

The University must return this amount even if it didn't keep this amount of the Title IV program funds. If the University is not required to return all of the excess funds, the student must return the remaining amount. Any loan funds that must be returned, the student must repay in accordance with the terms of the promissory note. That is, scheduled payments are made to the holder of the loan over a period of time. Students who have received a refund of their loan proceeds before withdrawing may be required to return part or all of those funds to the lender.

Title IV funds will be returned in the following order:

• Unsubsidised Federal Direct Loans
• Subsidised Federal Direct Loans
• PLUS Loan Funds

The requirements for Title IV program funds when students withdraw are separate from any refund policy that the University may have. Therefore, the student may still owe funds to the University to cover unpaid institutional charges. The University may also attempt to collect from the student any Title IV program funds that the University was required to return.

Students requesting a period of interruption should notify their School within 5 days. The Interruption date is the date the student completes this process; this date is entered on the University Student Information System. There must be a reasonable expectation that the students will return from the period of absence.

Interruption of Study retains the ‘in-school’ status for 180 days after which the student is reported as having been withdrawn. This may affect the student’s loans repayment grace period.

In determining the amount of loan funds that a student has earned upon withdrawal, UWS will calculate the percentage of the loan period attended. Programs are measured in credit-hours (Payment Period (PP)):

% of Title IV Earned =

# of days in attendance (less unscheduled leave over 5 days) /# of days in the PP

The treatment of Title IV Funds when a student withdraws from a credit hour programme is calculated using the Return to Title IV Worksheet.

UWS Finance Office will inform withdrawn students in writing of the amount that the student is obliged to return to the US Federal Aid programme, the amount (if any) that needs to be paid to the University by the student and the amount (if any) that is due to be refunded to the student by the University. Unearned Funds are the responsibility of the student and can be repaid under the terms of the Master Promissory Note.

NB: Where a student ceases to attend their selected programme but transfers to another programme in the same payment period, they are not considered to have withdrawn and are eligible to receive Title IV funds for which the student was eligible for before ceasing their attendance.

If a student did not receive their disbursement at the beginning of the payment period and decides to withdraw, the student is eligible for the amount of loan earned in this period.

The loan amount will be calculated and offered as post-withdrawal disbursement. The Title IV calculation will be performed and the student will be notified of any loan-overpayment or post-withdrawal disbursement.

Post-withdrawal disbursement will be made available to the student (or parent in the case of a Parent PLUS loan) within 180 days from the date of withdrawal.

UWS will provide written notification within 30 days of the date of the determination of the withdrawal and will detail:

• the type of loan and the amount
• the option to accept or decline some or all of the funds
• explain the obligation to repay any loan fund disbursed
• a deadline for a response, giving at least 14 days notice

UWS must receive confirmation from the student or parent borrower prior to any disbursement. This need not be in writing but must be recorded.

If the student responds after the deadline, UWS may choose to honour the late response at its discretion. However, after 180 days after the date of determination, UWS has no discretion and cannot disburse funds under any circumstances.

UWS must provide the students with the information set out in this policy.

UWS has a responsibility to return unearned aid, whichever is the lesser amount between the Title IV aid to be returned and the amount of unearned charges. UWS must perform the R2T4 calculation within 30 days from the date the student has completely withdrawn and the funds must be returned within 45 days of the calculation.

UWS will notify the student by email to their UWS email account should they be required to return any funds to the US government. The funds to be returned are sent to G5 (the federal payment disbursement system) via Western Union, who do the conversion from pounds to US Dollars.

UWS will inform the student of any balance owed to the University because of return of funds.

Student must follow the University’s procedure for ‘Withdrawal’.

Students should be aware of how any withdrawal will affect their eligibility to Title IV Federal Student Financial Assistance and that this policy exists.

Students should ensure that any outstanding balance owed to the University resulting from a return of unearned funds are met.

Student must return to Title IV any funds that were disbursed directly to the student and for which the student determined to be ineligible through the Return of Title IV Funds calculation.

Title IV

Title IV is a term that refers to federal financial aid funds. Federal regulations state that any federal funds disbursed to a student's account in excess of allowable charges must be delivered to the student (or parent in case of an undergraduate PLUS loan).

Amount of Title IV Earned by the Student

Where the percentage of aid earned is under 60%, the percentage calculated in Step 1 is multiplied by the total Title IV disbursed for the period, to give the amount of Title IV earned by the student i.e:

Total aid disbursed x percentage completed = earned aid

Amount of Title IV aid to be disbursed or returned

If the total aid that has been disbursed is less than the aid earned then a post-withdrawal disbursement will need to be calculated by the University i.e:

Total disbursed aid – earned aid = unearned aid to be returned

Master Promissory Note

The Master Promissory Note (MPN) is a legal document in which a student promises to repay their loan(s) and any accrued interest and fees to the U.S. Department of Education. It also explains the terms and conditions of the loan(s). Unless the school does not allow more than one loan to be made under the same MPN, students can borrow additional Direct Loans on a single MPN for up to 10 years.

Approved Interruption of Study (IS)

An Interruption of Study is a temporary interruption in a student’s programme of study. IS refers to the specific time period during a programme when a student is not in attendance and will return to complete the programme. Students returning from an IS are not required to re-apply for admission but must re-register for their programme.

Unapproved Interruption of Study (IS)

The School may grant a student an IS that does not meet the conditions to be an approved IS for Title IV purposes (for example, for academic reasons). However, any IS that does not meet all of the conditions for an approved IS, is considered a withdrawal for Title IV purposes.

Official Withdrawal

A "withdrawal" refers to a student’s intent to completely terminate studies at UWS with no expectation of return. Students who subsequently decide to return to their studies must re-apply for admission through the University’s Admissions Office.

Unofficial Withdrawal

An unofficial withdrawal is one where the School has not received notice from the student that he or she has ceased, or will cease, attending the programme.

UWS is bound by the FSA regulations in force at the time. The latest procedures and regulations for foreign schools can be found in the Federal Register (Part II) - Foreign Institutions - Federal Student Aid Programs (Final Rule) 2010.