Return of Title IV Funds (With Changes from HERA) Hi.ppt

Return of Title IV Funds  (With Changes from HERA) Higher Education Reconciliation Act of 2005 (P. L. 109-171) Brian Kerrigan Dan Klock Today’s Agenda DCL issues Regulation changes from HERA R2T4 calculation with HERA changes Compliance self-monitoring Questions answers Presentation Objectives Bring you up to date on R2T4 changes Demonstrate changes in calculation Understand that R2T4 non-compliance is a top finding Answer questions Dear Colleague Letter  (GEN-04-03)  Dear Colleague Letter (GEN-04-03) Title IV credit balance Aid that could have been disbursed Verification not completed before withdrawal No passing grades Withdrawal – credit hr, non-term program Date of determination of withdrawal for institution required to take attendance Title IV Credit Balances Hold credit balance - do R2T4 first Credit balance is “Aid Disbursed” See if credit balance changes because of R2T4 Repay grant overpayment on behalf of student Release credit balance within 14 days Aid That Could Have Been Disbursed All aid for period, if late disbursement conditions met before student withdraws (668.164(g)(2)) However, if limitations apply, aid may not be paid to student (668.164(g)(4)) Conditions for a Late Disbursement(need to be before student withdraws) For all aid (except PLUS) – process date for official EFC on SAR / ISIR For FFEL / Direct Loan – loan certified or originated For Perkins / FSEOG – award made Limitations on Making Late Disbursement No second or subsequent disbursement of FFEL / DL, unless student completes period No FFEL / DL unless student completes 30-day delay period Limitations on Making Late Disbursement No Pell Grant without valid SAR / ISIR by deadlines in Federal Register No 2nd pp Pell if 1st pp not completed No 2nd pp FFEL / DL if 1st pp not completed Verification Must complete R2T4 within 45 days If verification not completed Return interim disbursements of aid Only unsubsidized and PLUS lo