Is a Student a Withdrawal If She Completes All Clock Hours Early Without Completing All Scheduled Weeks Of Instruction?

No, according to guidance NASFAA has received from the U.S. Department of Education (ED).

Under the R2T4 regulations effective July 1, 2021, if the student completes all the requirements for graduation before completing all of the clock-hours or days in the payment period or period of enrollment, the student is not considered to have withdrawn and is exempt from the R2T4 calculation. However, if a clock-hour student graduates without successfully completing all of the established clock hours in the program, the school must re-prorate the amount of Title IV aid and only pay the student for the clock hours the student successfully completed.

Per ED, if a student successfully completes all clock hours within a program before the normal number of weeks have elapsed, the student is not considered a withdrawn student and no proration (or re-proration) of Title IV aid has to occur. This is due to the fact that students progress individually through clock-hour programs and though an overall program length in weeks that is reported to ED. Those weeks are an estimate of how long it normally takes the majority of the school's full-time students to complete the program of study. Therefore, it is not uncommon to have some students complete a program a little earlier or later than the reported number of weeks have elapsed. However, the number of clock hours that make up a program of study are static for all students and do not change. The re-proration requirement is only for situations where the student completed a program without successfully completing all of the established hours in the program (not the weeks).

Of course, if a majority of students are completing the program in less weeks than reported to ED on the E-App, then the school will need to review and adjust the number of weeks it normally takes the majority of their full-time students to complete the program of study. And just as a reminder, if a student successfully completes all of the hours in the program before completing a sufficient number of weeks to enter the final payment period, the student will not qualify for any final Title IV disbursements.

Reference the following:

• September 2, 2020 Federal Register
• ED Program Integrity Questions and Answers—Return of Title IV Fund website Q&As CHP-Q1-Q4/A1-A4
• NASFAA Decision Tree: R2T4 Decision Tree--Determining Whether a Student Has Withdrawn from a Nonterm or Subscription-Based Program [Effective July 1, 2021]
• ED Webinars: R2T4 -- July 1, 2021 New Rules FSA Webinar 041221 and R2T4 for Modules FSA Webinar April 2022