Are We Required To Redo the R2T4 Calculation If We Implement the R2T4 Waiver and Re-Disburse Title IV Aid?

This AskRegs Knowledgebase Q&A was updated on February 1, 2023 to note that the COVID-19 national emergency will end on May 11, 2023.

NASFAA has now confirmed with the U.S. Department of Education (ED) that, when the school had already performed the return of Title IV funds (R2T4) calculation and returned Title IV aid for the covered period (see below), the school does not need to redo or undo the R2T4 calculation. The determination of unearned aid is based on the original R2T4 calculation. Redoing the calculation would yield the same result anyway. The school just needs to retain documentation of the original R2T4 calculation in order to complete the required R2T4 reporting later.

In situations like this, the school should follow the guidance in AskRegs Q&A, How Do We Implement the R2T4 Waiver If We Are Re-Disbursing Aid We Already Returned Under the R2T4 Calculation?

R2T4 waiver refers to the fact that the CARES Act, waives the requirement for the school or the student to return Title IV funds when a student withdraws due to COVID-19 anytime during the entire payment period that falls within the covered period.

Covered period refers to the fact that the May 15, 2020 Electronic Announcement now allows schools to apply the R2T4 waiver to: 1) payment periods or periods of enrollment that include March 13, 2020; or 2) payment periods or periods of enrollment that begin between March 13 and the later of December 31 or the last date that the national emergency is in effect; the national emergency is now set to end May 11, 2023.

Payment Period Or Period of Enrollment: Remember that standard term programs must use the standard term payment period (semester, trimester, quarter) in the R2T4 calculation; they do not have the option to use the period of enrollment. A nonterm or nonstandard term program has a choice to use either the payment period or the period of enrollment in the R2T4 calculation. Therefore, it is NASFAA's understanding (because the Electronic Announcement language is unclear) that whichever period is used in the R2T4 calculation requires a determination of whether a student withdrew during that payment period or period of enrollment due to COVID-19.

August 21, 2020 Electronic Announcement Update: "Where an institution has opted to use the period of enrollment to calculate its returns for a non-term or non-standard term program, the waiver may apply to a student who begins attendance in a payment period that includes December 31, 2020 or the last date that the national emergency is in effect and withdraws after the conclusion of that payment period but within the applicable period of enrollment."

See also the following AskRegs Q&As:

• How Do We Determine If a Withdrawal Was the Result Of a Qualifying Emergency Due To Coronavirus?
• How Do We Implement the R2T4 Waiver If We Are Performing the First R2T4 Calculation For the Student?
• What Are the R2T4 Reporting Requirements Under the CARES Act?

Notes:

• This AskRegs Q&A was previously updated on August 25 to include clarification from the August 21, 2020 Electronic Announcement for nonterm and nonstandard term programs that use the period of enrollment (rather than the payment period) in their R2T4 calculations.
  
• This AskRegs Q&A was previously updated on June 17, 2020 to reflect June 16, 2020 changes to the May 15, 2020 Electronic Announcement, which expands the terms and nonterm payment periods to which the R2T4 waiver now applies, as well as clarifies that the determination of COVID-19 related withdrawals are made on a payment period-by-payment period or period of enrollment-by-period of enrollment basis.
• This AskRegs Q&A was previously updated to clarify guidance provided in NASFAA's May 20, 2020 COVID-19 webinar, as it relates to when the school chooses to implement the R2T4 waiver under the May 15, 2020 Electronic Announcement.