Return of Federal Student Aid (Title IV) Funds Policy
A Return to Title IV (R2T4) calculation is required when a student does not attend all of the days the student was scheduled to complete within a payment period or period of enrollment. This policy applies to all students who officially withdraw, unofficially withdraw, or are administratively dismissed while receiving Title IV aid. The R2T4 calculation is done to determine the amount of Title IV aid earned by the student.
The students affected by this policy are determined according to the following definitions listed below:
An official withdrawal occurs when a student provides written or electronic notice to the Registrar or completes the university’s withdrawal process. In such cases, the withdrawal date is the date the student begins the withdrawal process or notifies the institution of intent to withdraw.
An unofficial withdrawal occurs when a student ceases enrollment without notification and fails to earn a passing grade in all courses for the term. Because La Roche University does not take attendance after the census date, the withdrawal date for these students is the respective term midpoint, unless faculty can document a later academically related activity, such as an exam, paper submission, or project participation, as required by 34 CFR 668.22(c)(3)*.
When a student who receives a disbursement of Title IV funds then ceases attendance prior to the 60 percent point in the payment period, La Roche University will determine whether the student must repay a portion of the disbursement. A statutory prorated schedule will be used to determine the percentage of Title IV funds the student has earned at the time of withdrawal. Federal Work Study funds are excluded from the calculation.
If a student withdraws after completing more than 60 percent of the semester/term, all Title IV aid is considered earned and the student does not owe a repayment. However, withdrawing may affect a student’s satisfactory academic progress and eligibility for future financial aid.
Modular (Subterms) Courses and Return to Title IV
A student who withdraws from a subterm course (1st 8 weeks or 2nd 8 weeks) within the semester is considered to be withdrawn, even if registered for future classes starting in the same semester, unless one of the following criteria is met:
- The student, at the time of withdrawal from a subterm class, is attending another class.
- The student has successfully completed course work in 49 percent of the countable days within the semester. Calculations cannot be rounded up to achieve 49 percent.
- The student has successfully completed courses that constitute half-time (6 credit hours) enrollment in the semester.
- The student provides documentation to the college indicating the intent to attend a future class within that semester.
If none of these criteria are met, the student is considered withdrawn and an R2T4 calculation must be completed. If the student provides documentation but doesn’t actually attend that future class, an R2T4 calculation is still required.
Return to Title IV Calculation
1. La Roche University calculates the percentage of Title IV aid earned based on a student’s attendance through the determined withdrawal date. The institution identifies the total number of calendar days completed in the payment period and the total number of days the student was scheduled to complete in that period. The percentage completed is determined by dividing the days attended by the days scheduled. To calculate the amount of aid earned, this percentage is multiplied by the total Title IV aid for which the student is eligible. When determining the length of the payment period or period of enrollment, scheduled breaks of five consecutive days or more are excluded from both the total term length and the student’s attendance period, provided the student’s last date of attendance occurs after the break.
2. The institution will then determine the total institutional charges (tuition, fees, and books and supplies charged at the bookstore) and multiply the total institutional charges by the percentage determined in step 1 above in order to calculate the earned charges.
Note that eligibility for a post-withdrawal disbursement (PWD) will be confirmed within 30 calendar days of the date that the student withdrew. The student or parent will have 14 calendar days from the date that La Roche University sent the PWD notification to accept a PWD. If a response is not received from the student or parent within the allowed time frame or the student declines the funds, La Roche University will return any earned funds that the school is holding to the Title IV programs.
In accordance with federal regulations, when Title IV financial aid is involved, the calculated amount of R2T4 funds is returned in the following order:
- Federal Direct Unsubsidized Loan Program;
- Federal Direct Subsidized Loan Program;
- Federal Direct Graduate PLUS Loan Program;
- Federal Direct Parent PLUS Loan Program;
- Federal Pell Grants;
- Iraq and Afghanistan Service Grant (IASG);
- Federal Supplemental Educational Opportunity Grant (FSEOG) Program; and,
- Federal TEACH Grants.
Students are encouraged to officially withdraw to ensure accurate processing of their financial aid. Students remain responsible for any outstanding tuition, fees, or balances that result from the return of Title IV funds. The institution, in turn, is responsible for monitoring grade records to identify unofficial withdrawals, documenting withdrawal dates and R2T4 calculations, and ensuring timely communication and compliance with federal timelines. La Roche University maintains all records of withdrawal determinations and R2T4 calculations for audit and program review purposes.
Note, effective January 1, 2026, the regulations—outlined in the January 3, 2025, Federal Register—amend § 668.22(a)(2)(ii)(A)(6) to provide an exemption from the Return of Title IV Funds calculation when the following conditions are satisfied:
- The student is treated as never having begun attendance for Title IV purposes.
- The institution returns all Title IV, HEA assistance disbursed to the student for that payment period or period of enrollment.
- The institution refunds all institutional charges to the student for that period.
- The institution writes off or cancels any balance owed by the student due to the return of funds.
*An institution that is not required to take attendance may use as the student's withdrawal date a student's last date of attendance at an academically-related activity provided that the institution documents that the activity is academically related and documents the student's attendance at the activity.