Return Policy of Title IV Funds

Note: Any change in a student's enrollment must be reported to the financial aid office.  Students withdrawing from classes during the term are subject to federal and institutional refund and Return of Title IV Funds policies.

General Requirement

The Return of Title IV fund Policy is designed to ensure the accurate and timely determination of

1. The date of the institution’s determination that a student withdrew,
2. The student’s withdrawal date, and
3. The student’s last date of attendance 

The policy maintains the proper nature of Title IV funds, in accordance with 34 CFR 668.22 of the Code of Federal Regulations. Reference: 2021–2022 Student Financial Aid Handbook, Vol. 5, Ch. 1 pp. 5–53

When a recipient of Title IV grant(s) and/or loan(s) withdraws from Fordham University during a payment period in which he/she began attendance, the college must determine the amount of the grant and/or loan assistance earned by the student as of his/her withdrawal date. This policy establishes steps that Fordham University must take to ensure compliance with federal regulations.

Policy

Fordham must always return any unearned Title IV funds that it is responsible for within 45 days of the date Fordham determined the student withdrew and offer any post-withdrawal disbursement of loan funds within 30 days of that date. 
Reference: 2021–2022 Student Financial Aid Handbook, Vol. 5, Ch. 1 pp. 5–53

Withdrawal Date

A student’s withdrawal date varies depending on the type of withdrawal – official or unofficial. Reference: Determining a student’s withdrawal date at a school that is not required to take attendance in the 2021–2022 Student Financial Aid Handbook, Vol. 5, Ch. 1 pp. 37–39.

The Office of Academic Records enters the withdrawal, the withdrawal reason, and the date in Banner.  The Financial Aid Office initiates a refund worksheet for students who have Title IV aid and calculates the appropriate refunds, notifying the appropriate offices of adjustments and refunds.

Official Notification Provided

In a case when the student provides official notification of his/her intent to withdraw, Fordham will use the date of notification as follows: 

• In the event that a student sends written notification of intent to withdraw via a University Withdrawal/LOA Form, the date written upon the form in the “Last date of Academic Related Activity” is the date of withdrawal. 
• In the event that a student makes a notification to the Dean’s Office, the Dean’s Office notes the “last day of academic related activities,” then this date will be the date of withdrawal. 

*To begin the withdrawal process, the student contacts their respective Dean’s Office to obtain the appropriate withdrawal form.  

Official Notification Not Provided

In a case when the student does not provide official notification of his/her intent to withdraw, Fordham may use the midpoint of the payment period as the date of withdrawal, with the following exception: 

• When an official notification was not provided by the student because of circumstances beyond his/her control (i.e., illness, accident, grievous personal loss, or other circumstances), the date of the onset of such circumstances will serve as the withdrawal date as determined by the Dean’s Office. 
• The student received grades of WFs, Fs, NGRs, INC, etc. and/or failed to earn passing grades. 
• Dean’s Office provides “last day of academic related activities,” then this date will be the date of withdrawal.

Last Date of Attendance

Fordham may use as the withdrawal date the student’s last date of attendance at an academic activity reported by a faculty member or the Deans Office. Examples of academic activities include, but are not limited to, classes, exams, tutorials, computer-assisted instruction, academic conferences, turning in class assignments, attending a study group assigned by the college, or dissertation mentoring. The Dean’s Office/Academic Records will maintain documentation of the last date of attendance.

Date of Official Notification Not Provided

This is the date that Fordham learns the student has ceased attendance. Fordham will perform the Return to Title IV Funds calculation and return any unearned funds no later than 45 days after the end of the payment period. For a student who unofficially withdraws (e.g. does not provide official notification to Fordham that he/she is withdrawing), Fordham must determine the withdrawal date no later than 30 days after the end of the earliest:  1. Payment period or period of enrollment (as appropriate), 2. Academic year, or 3. Educational program. 
Reference: 2021–2022 Student Financial Aid Handbook, Vol. 5, Ch. 1 pp. 37

Rescission of Withdrawal

Fordham may allow a student to rescind an official notification to withdraw by having him/her file a written statement that he/she is continuing to participate in academic activities and intends to complete the enrollment period. If the student subsequently ceases to attend the institution prior to the end of the payment period, the rescission is negated, and the withdrawal date will be the last date of attendance at an academic activity. If the student subsequently withdraws (without ever returning to college) after rescinding an intent to withdraw, the rescission is negated, and the withdrawal date will revert back to the date of the first official notification. 

Calculation of Earned Title IV Assistance

U.S. Department of Education software (i.e. R2T4 tool in COD) will be used to perform all federal refund calculations. A copy of the completed calculation worksheet will be kept in the student’s file in the Office of Financial Aid. The amount of Title IV assistance earned by the student is calculated by determining the percentage of grant and/or loan assistance earned by the student, and applying that percentage to the total amount of grant and/or loan assistance disbursed to the student or on the student’s behalf for the payment period, as of his/her withdrawal date. The percentage of Title IV assistance earned will be equal to the percentage of the payment period completed by the student, when said percentage is less than 60 percent. If the student’s withdrawal date occurs after the completion of 60 percent of the payment period, the percentage earned is 100 percent. 

Treatment of Title IV Credit Balances when a Student Withdraws

Students, who withdraw, officially or unofficially, may be subject to adjustment of their financial aid packages and tuition charges.  There are three refund policies: Pro Rata (adjustment of charges based on a prorated amount), Federal (R2T4), and Institutional (adjustment of institutional aid based on the proration of tuition and/or room & board). One of these three will be applied wherever applicable.  Students considering withdrawal should come to the Office of Student Financial Services or contact the Office of Student Financial Services prior to withdrawal so that they can be advised as to the impact on their financial aid.

Per cash management regulations, Fordham must refund a Title IV credit balance to a student within 14 days. However, when a student withdraws and had federal aid on his/her account, Fordham must perform an R2T4 calculation to determine whether adjustments to the credit balance will occur. As a result, the existing 14-day payment requirement is placed on hold to determine the final amount of any Title IV credit balance. Fordham does not obtain a student’s or parent’s authorization to hold a Title IV credit balance that existed prior to the return calculation (beyond the original 14-day deadline) while it determines the final amount of the credit balance. In order to allow time to appropriately apply any credit balance after it has been recalculated, a new 14-day deadline is triggered when a R2T4 calculation is performed. The new 14-day deadline begins on the date the R2T4 calculation is performed. Note: in order to determine the correct Title IV credit balance, Fordham takes into account both the results of the R2T4 calculation and our institutional refund policy.

a. A student is not considered to have withdrawn if the student successfully completes one module that includes 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 

b. A student is not considered to have withdrawn if the student successfully completes a combination of modules that when combined contain 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 

c. A student is not considered to have withdrawn if the student successfully completes coursework equal to or greater than the coursework required for the institution’s definition of a half-time student under 34 CFR 668.2(b) for the payment period 

Leave Of Absence

For Title IV fund purposes, a leave of absence will be treated as a withdrawal. Students can receive an authorized leave of absence from Fordham by filing a written request to the Dean’s Office.  Their institutional scholarship aid can be restored within one academic year, providing they reapply for it in writing.  Study at another institution will cause the student to be viewed as a transfer student.  Previous aid offers are null and void and will not influence the new financial aid determination.  

Students who have completed one year’s leave of absence, but are now in their second or subsequent year of leave of absence, may reapply for institutional aid prior to their return; however, there is no guarantee institutional aid can be given.  

Withdrawal from Session Classes

A Session Class is defined as a course in a program that does not span the entire length of the payment period or the period of enrollment. A student who registers for a Session Class and then ceases to attend or fails to begin attendance is considered withdrawn, if he/she is not attending any other classes and is not registered for a Session Class to begin at a later date within the enrollment period. A student is not considered to have withdrawn if the college obtains written confirmation at the time of withdrawal that he/she will attend a Session Class to begin later in the same period of enrollment. This confirmation must be obtained at the time of withdrawal, even if the student has already registered for subsequent courses. If the student fails to return for the subsequent Session, the date of withdrawal reverts back to the original withdrawal date in the earlier Session. 

Date of the Institution’s Determination that the Student Withdrew

Some aspects of the withdrawal process cannot occur until the school is aware that the student has withdrawn. For example, a school cannot be expected to return Title IV funds for a withdrawn student unless the school knows that the student is no longer in attendance.  The “date of the institution’s determination that the student withdrew” captures the point in time when a school could reasonably be expected to be aware that a student withdrew. 

As noted above, the “date of the institution’s determination that the student withdrew” is not necessarily the same as a student’s withdrawal date. A student’s withdrawal date is used to determine the percentage of the payment period or period of enrollment completed and, therefore, the amount of aid a student has earned. The date of the institution’s determination that the student withdrew is used in the following circumstances: 

• A school must offer any amount of a post-withdrawal disbursement that is not credited to the student’s account within 30 days of this date; 
• If the student or parent submits a timely response that instructs the school to make all or a portion of the post-withdrawal disbursement, the school must disburse the funds within 90 days of this date; 
• A school must document a student’s withdrawal date and maintain the documentation as of this date; 
• Within 30 days of this date, a school must notify a student if a grant overpayment is due; 
• A school that is collecting an overpayment must require repayment of the full amount of the overpayment within two years of this date; 
• The school must return the amount of Title IV funds for which it is responsible no later than 45 days after this date; and 
• The amount of aid disbursed as of this date is used to determine the amount of unearned aid that must be returned. 

Post-Withdrawal Disbursements

If the total amount of the Title IV grant and/or loan assistance earned by the student is more than the amount that was disbursed to the student as of the withdrawal date, the difference between the two amounts will be treated as a post-withdrawal disbursement. In the event of outstanding charges on the student’s account, Fordham will credit his/her account for all or part of the amount of the post-withdrawal disbursement, up to the amount of allowable charges.

If Direct Loan is used to credit the student’s account, Fordham will notify the student (or parent for a PLUS Loan) and provide the student (or parent) with the opportunity to cancel all or a portion of the loan(s). 

Any amount of a post-withdrawal disbursement that is comprised of loan funds and has not been credited to a student’s account will be offered to the student (or parent for a PLUS Loan) within 30 days of the date the college determined the student’s withdrawal. Any earned grant funds that the student is eligible to receive due to a post-withdrawal disbursement will be provided within 45 days of the date of determination. Students (or parent for a PLUS loan) will be notified of such disbursements in writing.
The notification will include: 

• Identification of the type and amount of the Title IV funds that make up the post-withdrawal disbursement (not to include any amounts that have been applied to the student’s account) 
• Explanation that the student (or parent for a PLUS loan) may accept or decline some or all of the post-withdrawal disbursement (that which has not been applied to the student’s account) 
• Advisement that Fordham is not required to make a post-withdrawal disbursement if the student (or parent for a PLUS Loan) does not respond within 14 days of the date that Fordham sent the notification 

Upon receipt of a timely response from the student (or parent for a PLUS loan), Fordham will disburse funds in the manner specified in the response. Distribution will occur within 180 days of the date of determination of the student’s withdrawal date. If no response is received from the student or parent, Fordham will not disburse the funds. Fordham maintains the right to decide whether or not to make a post-withdrawal disbursement in the event that the student (or parent for a PLUS Loan) responds after 14 days of the date that notification was sent to them. If Fordham decides not to make this post-withdrawal disbursement, it will inform the student (or parent for a PLUS Loan) in writing. In the case of a post-withdrawal disbursement, grant funds will be disbursed prior to loan funds. 

Refund of Unearned Funds to Title IV

If the total amount of Title IV grant and/or loan assistance that was earned by the student is less than the amount that was disbursed to the student as of the withdrawal date, the difference between the two amounts will be returned to Title IV programs and no further disbursements will be made.  

Refunds by the University 

In the event that Fordham is responsible for returning funds to Title IV programs, the funds will be returned in the order prescribed by the U.S. Department of Education (listed below) within 45 days of the date of determination of a student’s withdrawal. 

• Unsubsidized Federal Direct Loans 
• Subsidized Federal Direct Loans 
• Federal Direct PLUS 
• Federal Pell Grants
• Iraq and Afghanistan Service Grant
• Federal Supplemental Educational Opportunity Grants (FSEOG) 
• Teacher Education Assistance for College and Higher Education Grant (TEACH) 

Refunds by the Student 

In the event that the student is responsible for returning grant funds to Title IV programs, Fordham will notify the student within 45 days of the date of determination of his/her withdrawal. The student will be advised of making arrangements for repayment. 

Payment Period or Enrollment Period

Withdrawals and the return of Title IV funds will be based on a payment period for all standard term programs. 

Program Course Offered in Modules 

For a payment period or period of enrollment in which courses in the program are offered in modules: 

• A student is not considered to have withdrawn if the institution obtains written confirmation at the time of withdrawal of an anticipated return date to a module to begin later in the same payment period or period of enrollment. 
• A student may change the date of return to a module that begins later in the same payment period or period of enrollment, provided that he/she does so in writing prior to the previously confirmed return date. 
• If an institution obtains written confirmation of future attendance, but the student does not return as scheduled, he/she is considered to have withdrawn from the payment period or period of enrollment. 
• A student’s withdrawal date and the total number of calendar days in the payment period or period of enrollment will be treated as if he/she had not provided written confirmation of a future date of attendance (original withdrawal date). 
• If a student withdraws from a program offered in modules during a payment period or period of enrollment and re-enters the same program prior to the end of the period, he/she is eligible to receive Title IV, HEA program funds for which he/she was eligible prior to withdrawal. This includes funds returned by the institution or student, provided the student’s enrollment status continues to support the full amount of those funds. 

Reviewing Students Who Withdrew from the University

On at least a bi-weekly basis a report is run named R2T4 Report. This picks up any students who have withdrawn from Fordham.  Also, as a "University Withdrawal/LOA Form" is received by Academic Records, a copy is sent to Student Financial Services.  A determination is made as to whether the student has received Title IV funding and if funds need to be returned according to the calculation worksheet in the R2T4 tool in COD.  Data is entered onto the federal website for the R2T4 calculation to determination the percentage of aid earned. 

Documentation

Fordham documents a student’s withdrawal date and the date of determination that the student withdrew. The documents will be kept in the student’s file in the Dean's Office/Academic Records and Office of Financial Aid, in the case of an Official Withdrawal. Unofficial withdrawal dates are reviewed in conjunction with Student Information software and the student’s respective Dean’s Office.  The Title IV funds calculation and its accompanying documentation will be secured in the Office of Financial Aid.