Return of Title IV Funds

Western Wyoming Community College (Western Wyoming Community College) has a clearly defined procedure for student refunds for educational costs such as tuition and fees, room and board when an official withdrawal is completed. See Policy 3810B for the college-wide refund process for tuition and fees and refer to the Residence Halls Handbook for refund tables for housing and meal plans. However, this policy differs from the federal policy of returning funds for students who require a Return to Title IV calculation to be performed.  The Return to Title IV policy and procedure are defined here. Any student receiving Title IV funding is subject to a Return to Title IV calculation to determine the percentage of aid actually earned while in attendance.

The Return to Title IV is required to be performed by schools per federal regulation 34 CFR 668.22. Students are awarded Title IV aid under the assumption that the student will attend and complete courses for each period they receive Title IV aid. Students who attend and successfully complete courses for which Title IV aid was received are assumed to have earned 100% of the Title IV funding disbursed. Students who do not successfully complete the entire enrollment period due to withdrawal from courses (official or unofficial, will have a Return to Title IV calculation performed on their account to determine the percentage of aid earned.

Students earn a percentage of aid each day of the period enrolled, beginning on the first day of the period. When a student withdraws the date of that withdrawal is used to then determine the number of days attended. The number of days attended are then divided by the total number of days in that period.  This calculation results in the percentage of aid earned.

If the amount of aid disbursed to the student is greater than the amount of aid the student earned, the unearned funds must be returned to the Department of Education.  If the amount of aid disbursed to the student is less than the amount of aid the student earned, and for which the student is otherwise eligible, the student is eligible to receive a post-withdrawal disbursement of the earned aid that was not yet disbursed.

Funds to be included in the Title IV calculation are as follows:

• Direct Unsubsidized Loans
• Direct Subsidized Loans
• Direct Parent Loans (PLUS)
• Federal Pell Grants
• Federal SEOG

Federal Work Study funds are NOT included in the calculation.

Official Withdrawal - Official withdrawals result when a student formally submits a total withdrawal form to Mustang Central. The withdrawal date is determined within 30 days of the date of withdrawal.

The date of determination is based on one of the following:

• The date the student begins the withdrawal process OR officially notifies the institution of intent to withdraw
• Date on the official Add/Drop form submitted to Records and Registration

Unofficial Withdrawal -  Unofficial withdrawals result when a student does not go through the official withdrawal process but, rather ceases attendance without providing notification to Mustang Central.

Western Wyoming Community College does not require attendance to be taken.  The date of withdrawal is determined by the date provided of the last Academic Related Activity.

Under some circumstances, attendance may be taken as required by:

• An outside entity (i.e., accreditor, state) for a particular student or cohort of students; or
• Western Wyoming Community College or an outside entity has a requirement that can only be met by taking attendance or a comparable process to demonstrate attendance in courses of that program or portion of that program.

The unofficial withdrawal date is determined within 45 days after the end of each semester.

Academic Related Activities include physically attending a course where the opportunity for direct interaction between the instructor and student such as:

• Submitting an academic assignment,
• Taking an exam
• Attending a study group assigned by the College,
• Participating in an online discussion about academic matters, and
• Contact initiated by the student with a faculty member regarding the subject matter being studied in the course.

Activities not considered Academically Related:

• Living in College housing,
• Participating in the College’s meal plan,
• Participating in academic counseling or advisement,
• Logging into an online course without active participation.

It is also not sufficient for a student enrolled in a distance education context, to only login into the course without active participation.  The College must demonstrate that a student has participated in an Academic Related activity, in order to be considered in attendance.

Withdrawal Dates when students are enrolled in Modules or Block Courses: If a student is enrolled in at least one module course then they are considered to be a module student. Certain conditions apply when determining a date of withdrawal for a student enrolled in modules or block courses.

1. After beginning attendance in the payment period or period of enrollment, did the student cease attendance or fail to begin attendance in a course they were scheduled to attend? If the answer is no, then the student is not considered to have withdrawn.  If the answer is yes, then proceed to the next question. 
2. If the student ceased attendance or failed to begin attendance in a course they were scheduled to attend, was the student still attending any other courses? If the answer is yes, then the student has not withdrawn; however other regulatory recalculation provisions may still apply. If the answer is no, continue to the next question.
3. Did the student submit confirmation that they would attend a module course beginning later in the period? (Attendance in this later course may be no later than 45 calendar days after the end of the module the student ceased attendance.) If the answer is yes, then the student has not withdrawn, unless the student does not return and begin attendance in the confirmed module course.  If the student did not submit confirmation of future attendance, it is a withdrawal and a Return to Title IV calculation must be performed and all Return to Title IV requirements apply.

Written confirmation is required to be submitted to the office of Financial Aid in Mustang Central for any student who ceases attendance in a module course but, plans to return to attend a future module course within the payment period or period of enrollment. Students may also reaffirm their intent to attend a future course by registering for a future course at the time of their withdrawal. If a student confirms future enrollment but does not return for the future module course, a Return to Title IV calculation must be completed.

Withdrawing prior to completing 60% of the term: Title IV aid is earned on a per day basis during the period of enrollment.  The College must determine through a Return to Title IV calculation that a student has earned 60% or more in the payment period or period of enrollment.  If a student has earned up to the 60% point in the payment period or period of enrollment, the student is considered to have earned 100% of the Title IV funds received. All Title IV aid is subject to a return of funds up to the 60% point. After the 60% point has been reached, all aid is considered "earned" and no funds are required to be returned. The College must determine whether a student who has earned 60% or higher is eligible for a post-withdrawal disbursement.  

Post Withdrawal Disbursement: The amount of a post-withdrawal disbursement is the difference between the amount of Title IV funds already disbursed and the amount of aid earned.

Western Wyoming Community College may not make a post-withdrawal disbursement of any of the following Title IV funds:

• Second or subsequent Direct Loan disbursements to any student who did not graduate or successfully complete the loan period.
• Direct Loan disbursement to a student who is considered a first-time, first year undergraduate who withdraws prior to completing the first 30 days of their program.
• Direct Loan disbursement to a borrower who has not completed Entrance Counseling and signed the loan’s Master Promissory Note.
• Disbursements of any Title IV funds to students for whom Western Wyoming Community College did not receive a valid Institutional Student Information Record (ISIR) prior to the student withdrawing or by the annual deadline published by the U.S. Department of Education in the Federal register.
• Federal Pell Grant, FSEOG, or Direct Loan disbursement for a subsequent payment period to a student who withdraws from a non-term credit hour program prior to completing the previous payment period for which the student had been paid.

Disbursement will be made up to 30 days from the date of determination of withdrawal.

Post-withdrawal notification:

• The College is permitted to credit a student’s account with the post-withdrawal disbursement of Title IV grant funds without the student’s permission.
• If the post-withdrawal disbursement is produced from a Direct Student Loan the College is required to notify a student, or parent for Direct Parent Plus Loan before making any post withdrawal disbursement of loan funds.
• Western Wyoming Community College will notify the student by email or letter sent through the US postal service, to request confirmation that the student, or parent, for Plus Loans, want to receive the post-withdrawal payment of loan funds.
• Notification will be sent within 30 days of the withdrawal date, and the student/parent will be given 14 days to respond.
• A written response from the student/parent will be required.
• If no response is received by the deadline established, Western Wyoming Community College is not required to make the post-withdrawal disbursement and funds will be returned to the Title IV programs.
• The College is permitted to choose to make a post-withdrawal disbursement when an acceptance is received after the College’s deadline. If the College chooses not to make the post-withdrawal disbursement when the acceptance was received after the deadline, the College must notify the student/parent in writing, that the disbursement will not be made and the reason why.
• If funds still remain after being applied to the student account, those funds will be disbursed as a direct disbursement to the student. This disbursement will be made as soon after the credit balance is determined but, no later than 14 days after the calculation of the Return to Title IV has been processed. 
• All loan funds accepted for post-withdrawal disbursement are funds that the student or parent, in the case of a parent Plus loan, will be responsible for paying back when entering repayment.

A sample worksheet used to calculate Return to Title IV Funds at Western Wyoming Community College is available at https://fsapartners.ed.gov/knowledge-center/fsa-handbook/2022-2023/vol5/appx-appendix-return-title-iv-aid-worksheets by selecting "Treatment of Title IV Funds When a Student Withdraws from a Credit Hour Program."

Returning Unearned Funds: If it is determined a student has unearned Title IV aid that was disbursed the College will  return the unearned portion of funds, up to the net amount disbursed from each source back to the proper Title IV programs.
Title IV aid is returned in the following order:

• Direct Unsubsidized Loans
• Direct Subsidized Loans
• Direct Plus Loans (PLUS)
• Federal Pell Grants
• Federal Supplemental Educational Opportunity Grant (SEOG)

Deadlines:

1. Within 30 days from the date the College determines the student has withdrawn, Western Wyoming Community College will offer a post-withdrawal disbursement, if applicable.
2. Within 45 days from the date the College determines a student has withdrawn, Western Wyoming Community College will return all unearned funds to the proper program(s). The student will be required to pay the funds to the College.
3. Students will be given 30 days from the date of notification to make payment in full or contact the Business office to discuss payment options and set up a plan for repayment. Failure to do so may result in the student becoming ineligible for future federal student aid.
4. Any unpaid balance on the student account will result in a hold being placed on the student account prohibiting future enrollment, receipt of transcripts, and is subject to the college's collection process.

Notification of Return of Title IV: The student will be sent a letter addressed to their current mailing address on file once the R2T4 calculation has been completed. The letter will indicate the following: percentage of aid earned, amount of aid unearned and to be returned, the current account balance, who to contact to set up an option for repayment, and the ramifications for unpaid balances.

Overpayment Resolution for Overpayments Occurring Prior to Withdrawal:

• For an overpayment made by the College that occurred prior to the student withdrawal, the College must repay the overpayment prior to conducting the R2T4 calculation. The overpayment is not to be included in the calculation.
• For a student liable overpayment that was determined to have occurred prior to the student withdrawing, the overpayment is not to be included in the R2T4 calculation.
  • If the student withdraws after the 60% point, the College should attempt to collect the overpayment from the student; if not successful, then the overpayment needs to be reported to the National Student Loan Data System (NSLDS) and referred to the U.S. Department of Education Default Resolution Group.
  • If the student withdraws prior to the 60% point, the College is permitted to reduce the post-withdrawal disbursement by the overpayment, or add the overpayment to the overpayment amount determined by the R2T4 calculation, whichever is applicable.

Special Circumstances: The College will use the date the College was notified that the student could no longer attend (i.e., hospitalization, death, incarceration, etc.) when a student is unable to complete the process of an official withdrawal due to extenuating circumstances.

Leave of Absence: Western Wyoming Community College has a leave of absence policy. Please see Student Leave of Absence Policy 5210B.

Western Wyoming Community College will not asses any additional institutional charges while the student is on an approved LOA or an unapproved LOA deemed to meet requirements for approval.

Western Wyoming Community College will report the student with a status of “A” to the National Student Loan Data Service (NSLDS)for enrollment reporting.

Western Wyoming Community College will not consider a student to have withdrawn if the following conditions are met:

• Student met conditions and all requirements in submitting the leave of absence and therefore, student was granted an approved leave of absence.

Disbursement of Aid while on LOA

Western Wyoming Community College will disburse Pell Grant and FSEOG funds per eligibility of Title IV funds.

Disbursement of Subsequent Aid:

• Western Wyoming Community College will not award any additional Title IV funds until the student completes coursework the student was enrolled when the leave of absence was granted.
• Upon the students return from the LOA the student will continue to earn Title IV aid previously awarded for the payment period.
• Western Wyoming Community College will distribute any credit balance in the form of a refund directly to the student.

Leave of Absence (LOA)when student is a Direct Loan Recipient:

• Western Wyoming Community College will maintain an in-school status for loan repayment purposes.
• Western Wyoming Community College will provide written communication to the student of possible consequences resulting from not returning from a LOA. This will include possible exhaustion of grace period and possible shift to repayment. Also, the students ability to speak with their loan servicer regarding possible deferment or forbearance of their loan payment if they enter repayment.

Failure to return from LOA:

Student who does not return within 180 days in a 12-month period of the LOA.

• Western Wyoming Community College will report to NSLDS the student as withdrawn and perform an R2T4 calculation using the date the LOA began as the withdrawal date.

Unapproved LOA

• Western Wyoming Community College is permitted to approve a LOA that does not meet the Title IV purposes, (i.e. Academic reasons) however, Western Wyoming Community College is required to consider this a withdrawal for Title IV funding purposes and will perform an R2T4 calculation as per federal regulations.

Questions about the Return to Title IV calculations may be directed to Mustang Central staff at (307) 382-1677, 1-800-226-1181 or finaid@westernwyoming.edu.