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Financial Aid & Scholarships

RETURN OF TITLE IV FINANCIAL AID POLICY (R2T4 POLICY)

BYU–Hawaii Federal Return of Title IV Funds (R2T4) Policies and Procedures

Reviewed/Revised: 11/14/2025

1. Purpose

The purpose of this policy is to establish clear, consistent, and compliant procedures for the calculation and return of Title IV federal financial aid funds when a student withdraws from BYU–Hawaii before completing the payment period or period of enrollment.
This policy ensures that:

  • BYU–Hawaii complies with the federal requirements outlined in 34 CFR 668.22 regarding the return of Title IV funds.
  • Title IV funds are returned in the correct order and amount when a student ceases attendance prior to completing more than 60% of the payment period or period of enrollment.
  • Students and BYU–Hawaii understand their respective responsibilities in the return process.
  • The calculation of earned and unearned aid is performed accurately and within the required federal time frames.
  • All returns and post-withdrawal disbursements are processed according to U.S. Department of Education regulations.

The overarching goal of this policy is to protect the integrity of federal financial aid programs and ensure equitable treatment of students who withdraw during a term.

2. Policy Statement

BYU–Hawaii is committed to complying with federal regulations governing the Return of Title IV Funds (R2T4) when a student who has received Title IV federal financial aid withdraws, officially or unofficially, from all courses prior to completing more than 60% of the payment period or period of enrollment.
In accordance with 34 CFR 668.22, BYU–Hawaii will:

  • Calculate the earned and unearned Title IV aid based on the student’s withdrawal date and the percentage of the payment period completed at the time of withdrawal.
  • Return unearned funds to the appropriate Title IV programs in the order prescribed by federal regulations, within the required 45-day timeframe.
  • Disburse post-withdrawal disbursements to students who are eligible, following federal timeframes and student authorization requirements.
  • Notify students of their responsibilities regarding any resulting balances owed to BYU–Hawaii after Title IV funds are returned.
  • Maintain documentation to support all withdrawal determinations, calculations, notifications, and returns as required under federal recordkeeping rules.

This policy applies to all students receiving Title IV federal aid who withdraw from BYU–Hawaii during a term, regardless of whether the withdrawal is official or unofficial. Financial Aid & Scholarships is responsible for ensuring accurate and timely implementation of this policy.

3.  Regulatory Authority

The Return of Title IV Funds (R2T4) process is governed by federal statutes and regulations established by the U.S. Department of Education. The primary regulatory authority for R2T4 includes, but is not limited to:

  • Higher Education Act of 1965, as amended
  • 34 CFR 668.22 – Treatment of Title IV Funds When a Student Withdraws
  • Federal Student Aid (FSA) Handbook – Volume 5: Withdrawals and Return of Title IV Funds
  • Dear Colleague Letters and Electronic Announcements issued by the U.S. Department of Education pertaining to R2T4 requirements
  • Program Participation Agreement (PPA) obligations for Title IV funds
  • NASFAA Standards of Excellence and Best Practices for compliance

BYU–Hawaii adheres to these regulations to ensure compliance with federal law, proper handling of unearned Title IV funds, and equitable treatment of students who withdraw during a payment period or period of enrollment.

4.  Definitions

For the purpose of this policy, the following terms are defined as required by federal regulations (34 CFR 668.22) and institutional procedures:

  • Title IV Funds – Federal financial aid programs authorized under Title IV of the Higher Education Act, including Federal Pell Grant, Federal SEOG, Direct Subsidized and Unsubsidized Loans, Direct PLUS Loans, and TEACH Grant.
  • Withdrawal – When a student ceases attendance in all courses for a payment period or period of enrollment, either through an official notification to BYU–Hawaii or by unofficially stopping attendance.
  • Official Withdrawal – A withdrawal initiated by the student through BYU–Hawaii’s published withdrawal process, including completion of required forms or communication with the Registrar or other designated office.
  • Unofficial Withdrawal – When a student stops attending all classes without providing official notification. The withdrawal date is determined based on the last date of academic activity as documented by faculty or institutional records.
  • Withdrawal Date – The date used to determine the amount of Title IV aid earned. For official withdrawals, this is the date the student begins the withdrawal process or provides official notification. For unofficial withdrawals, it is the last date of documented academic engagement.
  • Date of Determination (DOD) – The date BYU–Hawaii determines that the student withdrew. This date triggers the 45-day timeframe for returning unearned Title IV funds.
  • Earned Aid – The portion of Title IV aid a student is entitled to retain based on the percentage of the payment period or enrollment period completed prior to withdrawal.
  • Unearned Aid – The portion of Title IV aid that must be returned to the federal programs because the student did not complete the entire payment period or enrollment period.
  • Payment Period or Period of Enrollment – Defined according to the student’s enrollment type and program structure, as outlined in 34 CFR 668.4.
  • Institutional Charges – Charges for tuition, fees, and other educational expenses assessed by BYU–Hawaii for the payment period or period of enrollment, used in the R2T4 calculation.

5.  Roles and Responsibilities

To ensure compliance with federal regulations (34 CFR 668.22) and institutional policy, the following offices and staff members have defined roles and responsibilities for managing the R2T4 process:

Financial Aid & Scholarships

  • Calculate R2T4 in accordance with federal requirements within the 45-day deadline for returning unearned funds.
  • Review withdrawal notifications from the Registrar and other offices to determine the Date of Determination (DOD).
  • Determine earned versus unearned aid using the appropriate calculation formula.
  • Process returns of unearned Title IV funds to the appropriate federal programs in the correct order of return.
  • Initiate and process Post-Withdrawal Disbursements (PWD), including required notifications and obtaining student/parent authorizations where necessary.
  • Document all calculations and communications in the student’s financial aid record.
  • Maintain compliance with internal controls and audit requirements.

Registrar’s Office

  • Officially record student withdrawals and provide the withdrawal date to Financial Aid & Scholarships.
  • Notify Financial Aid & Scholarships promptly when a student initiates or completes the withdrawal process.
  • Provide last date of attendance or academic activity for unofficial withdrawals when requested.

Financial Services (Student Accounts)

  • Update student billing records to reflect institutional charges and credits after withdrawal.
  • Issue student refunds or return funds to the U.S. Department of Education as instructed by Financial Aid & Scholarships.

Academic Departments and Faculty

  • Document last date of academic activity (LDA) for students who cease attendance without officially withdrawing.
  • Provide timely response to Financial Aid & Scholarships requests for verification of attendance or academic engagement.

Compliance/Internal Audit (if applicable)

  • Review R2T4 processes and calculations for accuracy and compliance.
  • Ensure adherence to federal timelines and documentation standards.

6.  Determining Withdrawal Date

The determination of the student’s withdrawal date is critical for accurately calculating the amount of Title IV funds earned and unearned in compliance with 34 CFR 668.22. BYU–Hawaii uses the following guidelines:

Official Withdrawals

  • The withdrawal date is the date the student begins the withdrawal process as defined by BYU–Hawaii or the date the student officially notifies the school of their intent to withdraw, whichever is earlier.
  • If a student provides written or verbal notice of intent to withdraw, the date of that notification is used as the withdrawal date.
  • If the student withdraws without completing the official process but provides written confirmation of future attendance (within the same payment period), the withdrawal date will be adjusted accordingly.

Unofficial Withdrawals

  • For students who cease attending without official notice, the withdrawal date is the last date of documented academic activity (e.g., class attendance, submission of assignments, exam participation).
  • Faculty and academic staff must provide documentation of the student’s last date of participation when requested by Financial Aid & Scholarships.

Administrative Withdrawals

  • If the school initiates the withdrawal (e.g., for disciplinary or academic reasons), the official discontinuance date is the date BYU–Hawaii takes action to withdraw the student.

Date of Determination (DOD)

  • The Date of Determination is the date BYU–Hawaii becomes aware that the student has withdrawn.
  • The DOD is used to establish regulatory deadlines for R2T4 calculations (30 days for calculation, 45 days for return of funds).

Documentation

  • All withdrawal dates and DOD decisions must be documented in the student’s official record and maintained in accordance with federal and institutional recordkeeping requirements.

7. Calculation of Earned Aid

The calculation of earned Title IV aid determines the amount of aid a student is entitled to based on the percentage of the payment period or period of enrollment completed prior to withdrawal. This process follows the requirements of 34 CFR 668.22.

Step 1: Determine the Percentage of the Period Completed

  • Formula:

Percentage Completed=Number of Calendar Days CompletedTotal Calendar Days in the Payment Period or Enrollment Period\text{Percentage Completed} =
\frac{\text{Number of Calendar Days Completed}}{\text{Total Calendar Days in the Payment Period or Enrollment
Period}}Percentage Completed=Total Calendar Days in the Payment Period or Enrol lment PeriodNumber of Calendar Days Completed

  • Important Considerations:
    • Exclude scheduled breaks of 5 or more consecutive days.
    • Include the withdrawal date in the count of completed days.

Step 2: Apply the 60% Rule

  • If the student completes more than 60% of the payment period or period of enrollment, 100% of Title IV aid is considered earned, and no funds need to be returned.
  • If the student completes 60% or less, the percentage calculated above is applied to the total Title IV aid disbursed or that could have been disbursed.

Step 3: Calculate Earned vs. Unearned Aid

  • Earned Aid:  

Multiply the percentage of Title IV aid earned by the Total Title IV aid disbursed and that could have been disbursed for the period.
% of Title IV Aid [x] $ Total Title IV Aid Disbursed [=] Amount of Title IV Aid Earned

  • Unearned Aid:  

Add original charges for tuition, meals, and housing to determine total institutional charges for the period.

Multiply institutional charges for the period by the percentage of unearned Title IV aid to determine percentage of unearned Title IV aid.

$ Total Institutional Charges [x] % of Unearned Aid [=] Amount of Unearned Title IV Aid

Step 4: Compare Disbursed Aid to Earned Aid

  • If disbursed aid > earned aid, the difference must be returned to the Title IV programs.
  • If earned aid > disbursed aid, the difference may be eligible for a post-withdrawal disbursement (PWD), pending student or parent (for PLUS loans) confirmation and eligibility requirements.

Step 5: Order of Return of Unearned Funds

The return of Title IV funds is made in the following order:

  1. Unsubsidized Direct Loans (other than PLUS loans)
  2. Subsidized Direct Loans
  3. Direct PLUS Loans (Parent)
  4. Federal Pell Grant
  5. TEACH Grant

Rounding and Decimal Places

  • The earned aid amount is rounded to the nearest whole dollar.

Documentation
All calculations must be documented in the student’s file and retained in accordance with institutional and federal recordkeeping requirements.

8.  Post-Withdrawal Disbursements (PWD)

A Post-Withdrawal Disbursement (PWD) occurs when the amount of Title IV aid earned by the student (as determined by the R2T4 calculation) exceeds the amount of Title IV aid disbursed as of the withdrawal date. This section outlines the requirements and procedures for offering and disbursing PWDs in compliance with 34 CFR 668.22(a)(5), (i).

Eligibility for Post-Withdrawal Disbursement

  • The student must have earned more Title IV aid than was disbursed before withdrawal.
  • All conditions for a late disbursement must be met, as defined in 34 CFR 668.164(j):
    • The U.S. Department of Education processed a valid ISIR/SAR with an official SAI before the student became ineligible.
    • For Direct Loans, the loan must have been originated prior to withdrawal.
  • The student cannot be on financial aid suspension that would prevent disbursement prior to withdrawal.

Authorization Requirements

  • Grant Funds: Post-withdrawal disbursements of grant funds do not require student authorization and should be applied first to any outstanding institutional charges (tuition, fees, room, board).
  • Loan Funds: Loan PWDs require written confirmation from the student (or parent for PLUS loans) before disbursement. The school must notify the borrower and allow at least 14 calendar days to respond.

Notification to Student or Parent

  • Written notification must include:
    • Amount and type of PWD available.
    • Explanation of loan obligations and right to decline loan funds.
    • Deadline to respond (minimum 14 days).
  • Notification must be sent within 30 calendar days of the R2T4 determination.

Disbursement Timeframes

  • Grant Funds: Must be disbursed as soon as possible but no later than 45 days from the date of the R2T4 calculation.
  • Loan Funds: Must be credited to the student account or disbursed to the student (or parent) within 180 days of the student’s withdrawal date, provided borrower authorization is received.

Application of PWD to Charges

  • PWD grant and loan funds must be applied in the following order:
    • Current institutional charges (tuition, fees, room, board).
    • Other authorized charges (with student authorization).
  • BYU–Hawaii cannot automatically apply PWD to prior-year charges without written authorization.

Order of Disbursement


Grant funds are disbursed before loan funds to reduce the need for borrowing.

Documentation


Financial Aid & Scholarships must maintain:

  • Calculation worksheets showing PWD eligibility.
  • Student/parent communications and authorizations.
  • Disbursement records showing amounts, dates, and applications.

9.  Time Frames for R2T4

This section outlines the federally mandated timelines for performing R2T4 calculations, returning unearned funds, and processing post-withdrawal disbursements (PWDs) to ensure compliance with 34 CFR 668.22(j).

Key Deadlines and Requirements

1.  Withdrawal Date Determination

  • The withdrawal date must be established and documented immediately upon official or unofficial notification of withdrawal, per institutional policy.
  • Time-sensitive processes (e.g., R2T4 calculation) start upon the determination of withdrawal.

2.  R2T4 Calculation

  • BYU–Hawaii must perform the R2T4 calculation and determine earned vs. unearned aid within 30 calendar days of:
    • The date the school determines the student withdrew.

3.  Return of Unearned Funds

  • The school must return unearned Title IV funds to the U.S. Department of Education or applicable lender no later than 45 calendar days from:
    • The date the school determined the student withdrew.

Compliance Monitoring

  • Financial Aid & Scholarships is responsible for tracking all R2T4 deadlines to ensure timely processing.
  • Reports and alerts are generated from the student information system (SIS) to monitor pending deadlines.

10.  Funds to be Returned

This section establishes the requirements for determining the amount and order of Title IV funds that must be returned by BYU–Hawaii and/or the student when a withdrawal occurs, in compliance with 34 CFR 668.22.

Institutional Responsibility

  • BYU–Hawaii must return the unearned portion of Title IV funds for which it is responsible, within 45 calendar days of the date the school determined the student withdrew.
  • The amount of unearned funds to be returned by the school is the lesser of:
    • The total amount of unearned Title IV assistance, or
    • BYU–Hawaii charges multiplied by the percentage of unearned Title IV aid.

Student Responsibility

  • After the school returns its share, the remaining unearned Title IV funds are the student’s responsibility.· The student’s share is calculated based on the difference between:
    • The total unearned Title IV assistance, and
    • The amount returned by BYU–Hawaii.
  • Students are not required to immediately return grant funds that fall under the grant overpayment threshold ($50 or less).

Order of Return

Funds must be returned to Title IV programs in the following order, as required by federal regulations:

  1. Unsubsidized Direct Loans (other than PLUS loans)
  2. Subsidized Direct Loans
  3. Direct PLUS Loans (Parent)
  4. Federal Pell Grant
  5. TEACH Grant

Return Method

  • All returned funds must be processed through the U.S. Department of Education’s G5 system for federal grants or via the loan servicer for Direct Loans.
  • Documentation of all returns, including date, amount, and method, must be retained in the student’s financial aid file and reconciliation records.

Overpayments

  • If a student owes a Title IV overpayment:
    • Financial Aid & Scholarships must notify the student in writing within 30 days of the overpayment determination.
    • The student must make satisfactory arrangements to repay the funds or risk referral to the school. BYUH will return the funds to the U.S. Department of Education’s G5 system, and put the charge back on to the student account.

Internal Control Measures

  • Weekly compliance checks are performed to ensure that all required returns are initiated and completed within the federal 45-day deadline.
  • Reports from the student information system (SIS) and G5 return confirmations are reconciled monthly.

11.  Institutional and Student Responsibilities

This section outlines the respective responsibilities of BYU–Hawaii and students to ensure timely, accurate, and compliant implementation of the Return of Title IV Funds (R2T4) process.

Institutional Responsibilities

BYU–Hawaii is responsible for:

  1. Withdrawal Determination
    1. Identifying official and unofficial withdrawals.
    2. Determining the Date of Determination (DOD) in accordance with federal guidelines.
  2. R2T4 Calculation
    1. Calculating earned and unearned Title IV funds using the federal R2T4 formula.
    2. Applying the 60% rule for aid earned within the payment or enrollment period.
  3. Return of Funds
    1. Returning unearned Title IV funds for which BYU–Hawaii is responsible within 45 days of DOD.
    2. Processing post-withdrawal disbursements (PWD) according to federal regulations and student authorization.
  4. Notification and Documentation
    1. Informing students of their R2T4 results, overpayments, or post-withdrawal disbursements.
    2. Maintaining all required documentation in the student’s financial aid file for federal audit purposes.
  5. Compliance Monitoring
    1. Ensuring adherence to federal deadlines and reporting requirements.
    2. Reconciling returned funds to student accounts and federal systems.

Student Responsibilities

Students are responsible for:

  1. Official Withdrawal Notification
    1. Submitting official withdrawal requests according to institutional procedures.
    2. Providing accurate and timely information to facilitate withdrawal processing.
  2. Participation in R2T4 Process
    1. Responding to notifications regarding post-withdrawal disbursements, including loan acceptance or rejection.
    2. Complying with repayment obligations for Title IV funds considered student responsibility (overpayments).
  3. Communication
    1. Updating BYU–Hawaii with current contact information to ensure timely receipt of notifications related to R2T4 calculations, overpayments, and disbursements.

Collaborative Responsibility


Both BYU–Hawaii and the student share responsibility for:

  • Ensuring accurate and timely communication regarding enrollment status.
  • Facilitating compliance with federal R2T4 regulations to protect the student’s eligibility and BYU–Hawaii’s Title IV program integrity.

12.  Notification to Student

This section establishes BYU–Hawaii’s procedures for notifying students regarding their Title IV aid when a withdrawal occurs, ensuring transparency and compliance with federal regulations.

1. Withdrawal Notification

  • Students must be informed of their responsibility to notify BYU–Hawaii of withdrawal.
  • Financial Aid & Scholarships coordinates with the Registrar to confirm official or unofficial withdrawals.
  • Students who cease attendance without notification will be considered unofficial withdrawals, and notification procedures will be based on the last date of documented academic activity.

2. R2T4 Calculation Notification

  • After the R2T4 calculation is completed, students must be notified of:
    • The amount of Title IV aid earned and unearned.
    • The portion of funds returned by BYU–Hawaii.
    • Any remaining balance owed by the student to BYU–Hawaii or federal programs.

3.  Timing of Notifications

  • R2T4 calculation results and PWD notifications must occur within 30 days of the school’s Date of Determination (DOD).
  • Return of funds to Title IV programs by BYU–Hawaii must occur within 45 days of the DOD.

4.  Documentation

  • All notifications and student responses must be documented in the financial aid record.
  • Records must be maintained according to institutional policy and federal recordkeeping requirements (34 CFR 668.24).

13.  Late or Incomplete Withdrawals

This section defines procedures for handling students who withdraw late in the term or fail to complete the official withdrawal process, ensuring accurate calculation of earned and unearned Title IV funds in compliance with federal regulations.

1. Unofficial (Incomplete) Withdrawals

  • Students who cease attendance without providing official notification are considered to have an unofficial withdrawal.
  • Financial Aid & Scholarships will determine the withdrawal date based on the last date of documented academic activity, which may include:
    • Attendance in class or lab
    • Submission of assignments or exams
    • Participation in online coursework or discussions
  • Faculty and academic staff are responsible for providing accurate documentation of the last date of engagement when requested.

2. Late Withdrawals

  • For students who initiate a withdrawal late in the term, the withdrawal date is the date the student begins the withdrawal process or the date of official notification, whichever is earlier.
  • R2T4 calculations for late withdrawals follow the same formula for earned vs. unearned aid, applying the 60% rule.

3. Communication and Notification

  • Students involved in late or incomplete withdrawals must be notified in writing of:
    • The determination of their withdrawal date
    • The calculation of earned and unearned Title IV aid
    • Any post-withdrawal disbursement eligibility
    • Obligations for repayment of unearned funds

4. Documentation

  • BYU–Hawaii must retain:
    • Documentation of withdrawal date determination
    • Faculty verification of last date of attendance for unofficial withdrawals
    • Any adjustments made to the R2T4 calculation due to late or incomplete withdrawal
  • Documentation is maintained in the student’s financial aid record to support compliance and audit readiness.

14.  Overpayments

This section defines the procedures for identifying, notifying, and collecting Title IV overpayments resulting from student withdrawals, ensuring compliance with federal regulations.

1. Definition of Overpayment

  • A Title IV overpayment occurs when the total Title IV aid disbursed to the student exceeds the amount of aid the student earned for the payment period or period of enrollment.
  • Overpayments may include:
    • Grants (e.g., Pell, TEACH)
    • Loans (Direct Subsidized/Unsubsidized, PLUS)
    • Other Title IV assistance received for the same payment period

2. Identification of Overpayments

  • Overpayments are determined as part of the R2T4 calculation conducted by Financial Aid & Scholarships.
  • The calculation compares:
    • Total Title IV aid disbursed or eligible for disbursement
    • Earned aid based on the percentage of the period completed

3. Notification to Student

  • The student must be notified in writing of the overpayment, including the total amount owed
  • Notification must occur within 30 calendar days of the school’s R2T4 determination.

4. Documentation

  • Financial Aid & Scholarships must maintain:
    • Copies of all notifications sent to the student
    • Records of any repayment arrangements or payments received
    • Documentation of referrals to federal collection agencies
  • Records must be retained in accordance with institutional and federal recordkeeping requirements (34 CFR 668.24).

15.  Record Retention

This section establishes BYU–Hawaii’s requirements for maintaining and safeguarding records related to the Return of Title IV Funds (R2T4) process, ensuring compliance with federal regulations and audit readiness.

1. Retention Requirements

  • All records related to R2T4 calculations, student withdrawals, and fund returns must be retained for a minimum of three (3) years from the date the final R2T4 action is completed, unless federal or institutional policy requires a longer retention period.
  • Records include, but are not limited to:
    • Student withdrawal documentation (official or unofficial)
    • Date of Determination (DOD) calculations
    • R2T4 worksheets and calculations
    • Post-Withdrawal Disbursement (PWD) notifications and authorizations
    • Title IV overpayment notifications and repayment records
    • Documentation of fund returns to federal programs and reconciliation reports

2. Storage and Access

  • Records must be stored in a secure manner, either electronically or in paper format, to protect student privacy in compliance with FERPA.
  • Access to R2T4 records is limited to authorized personnel within Financial Aid & Scholarships, Compliance Office, and designated auditors.

3. Documentation of Communications

  • All communications with students regarding:
    • Withdrawal date determination
    • R2T4 calculations
    • Post-Withdrawal Disbursement eligibility
    • Overpayment notifications must be documented and retained in the student’s file.

4. Audit and Review Readiness

  • Retained records must be organized and readily available for review by:
    • Internal auditors
    • Federal program reviewers
    • State or accrediting agencies
  • BYU–Hawaii ensures that all R2T4-related documentation is complete, accurate, and accessible for compliance audits.

5. Disposal of Records

  • At the end of the retention period, records may be securely destroyed in a manner that protects sensitive student information, unless required to be retained longer due to federal, state, or institutional policy.

16.  Consumer Information

This section outlines BYU–Hawaii’s responsibilities for providing clear, accurate, and timely consumer information regarding the Return of Title IV Funds (R2T4) process to current and prospective students, ensuring compliance with federal disclosure requirements.

1. Availability of R2T4 Information

  • BYU–Hawaii must provide written information regarding the R2T4 process to students before they enroll.
  • Information must be included in:
    • The student handbooko The financial aid information packet
    • BYU–Hawaii’s website in an accessible format

2.  Information to be Provided

Students must be informed of:

  • Withdrawal and R2T4 Responsibilities
    • How official and unofficial withdrawals are defined
    • The student’s obligation to notify the school of withdrawal
    • How the withdrawal date is determined
  • Calculation of Earned and Unearned Aid
    • Explanation of the federal formula used to determine earned vs. unearned Title IV funds
    • The 60% completion rule and its impact on aid eligibility
  • Post-Withdrawal Disbursements (PWD)
    • Eligibility for PWD of grants and loans
    • Requirements for student authorization of loan funds
    • How PWD will be applied to institutional charges
  • Overpayment and Repayment Obligations
    • Student responsibility for unearned funds
    • Procedures for repayment and consequences of nonpayment
    • Thresholds for waived overpayments (e.g., $50 or less)
  • Institutional and Federal Contact Information
    • Whom to contact in Financial Aid & Scholarships for questions
    • U.S. Department of Education contact information for Title IV program inquiries

3. Updates and Revisions

  • Consumer information must be reviewed and updated annually or whenever federal regulations or institutional policies change.
  • Students must be notified of significant changes to R2T4 procedures that affect their financial aid eligibility.

4. Documentation

  • BYU–Hawaii must document that students received R2T4 consumer information, including:
    • Signed acknowledgment forms
    • Online access logs
    • Distribution records for handbooks or financial aid packets

17.  Staff Training

This section establishes BYU–Hawaii’s requirements for training Financial Aid & Scholarships staff to ensure accurate and compliant implementation of the R2T4 process in accordance with 34 CFR 668.22.

1.  Training Objectives

Staff training is designed to ensure that personnel:

  • Understand the federal regulations governing R2T4.
  • Can accurately calculate earned and unearned Title IV aid.
  • Know the procedures for returning unearned funds and processing post-withdrawal disbursements (PWD).
  • Are familiar with the notification requirements for students and parents.
  • Maintain proper documentation and record retention for audit readiness.

2.  Staff Roles and Responsibilities

Training must cover the responsibilities of:

  • Financial Aid & Scholarships Officers: Performing R2T4 calculations, applying the 60% rule, determining student eligibility for PWD, initiating fund returns.
  • Registrar/Academic Staff: Reporting last date of attendance for unofficial withdrawals.
  • Compliance/Operations Staff: Ensuring adherence to federal deadlines, reconciling returned funds, maintaining records for audits.

3. Training Frequency

  • Initial Training: All new staff must complete R2T4 training prior to handling student withdrawals or financial aid calculations.
  • Annual Training: All staff involved in the R2T4 process must complete refresher training at least once per year, including updates on regulatory changes.
  • Ad Hoc Training: Additional sessions are conducted as needed for changes in regulations, institutional policies, or system updates.

4.  Training Methods

Training may include:

  • In-person or virtual workshops
  • Hands-on practice with R2T4 calculation worksheets or student information systems
  • Review of case studies and prior R2T4 scenarios
  • Access to federal guidance, NASFAA resources, and internal procedure manuals

5. Documentation of Training

  • Financial Aid & Scholarships maintains records of:
    • Staff trained, including dates and topics covered
    • Attendance records for in-person or virtual sessions
    • Training materials and reference guides used
  • Documentation ensures audit readiness and supports institutional compliance reviews.

18.  Internal Controls

This section establishes BYU–Hawaii’s internal controls and procedures to ensure the accurate, timely, and compliant execution of the R2T4 process, while maintaining audit readiness and safeguarding Title IV program integrity.

1.  Internal Control Objectives

Financial Aid & Scholarships implements internal controls to:

  • Ensure accurate calculation of earned and unearned Title IV funds.
  • Comply with all federal deadlines for fund returns and post-withdrawal disbursements (PWDs).
  • Prevent errors or misreporting in student notifications, fund disbursements, and fund returns.
  • Maintain complete and audit-ready documentation for each R2T4 calculation and transaction.

2. Separation of Duties

  • R2T4 Calculations: Performed by designated financial aid staff independent of disbursement authorization.
  • Fund Returns: Reviewed and approved by a second staff member or supervisor before submission to the Department of Education or loan servicer.
  • Documentation Review: Compliance staff or an internal auditor periodically reviews R2T4 files for completeness and accuracy.

3. System Controls

  • Utilize the Student Information System (SIS) to:
    • Track enrollment and withdrawal dates.
    • Automate R2T4 calculations where possible.
    • Generate alerts for pending deadlines (e.g., fund returns, PWD notifications).
  • Maintain audit trails of all R2T4 calculations and disbursement actions.

4. Monitoring and Reconciliation

  • Perform regular reconciliation of:
    • Returned funds versus amounts calculated as unearned.
    • PWDs applied to student accounts and disbursed amounts.
    • Overpayments reported to the U.S. Department of Education.
  • Any discrepancies must be investigated and corrected immediately.

5. Audit Readiness

  • Ensure all R2T4 records are complete and organized for internal or external audits, including:
    • Student withdrawal documentation
    • Calculation worksheets
    • Fund return confirmations
    • PWD authorizations and communications
  • Conduct periodic internal audits or reviews to verify compliance with 34 CFR 668.22 and institutional policies.

6. Staff Accountability

  • Staff involved in R2T4 processes are required to:
    • Follow institutional procedures and regulatory guidance.
    • Attend annual training updates on R2T4 regulations.
    • Report any discrepancies or suspected errors to supervisors immediately.

19. Policy Review and Maintenance

This section establishes procedures for regularly reviewing and updating the R2T4 policies and procedures to ensure ongoing compliance with federal regulations and institutional standards.

1. Review Frequency

  • The R2T4 policy must be reviewed at least annually.
  • Reviews should also occur whenever there are:
    • Changes in federal regulations (e.g., 34 CFR 668.22–668.24)
    • Updates to institutional procedures, systems, or practices
    • Findings from audits or internal quality reviews that indicate policy adjustments are needed

2. Review Process

  • The Senior Manager of Financial Aid & Scholarships is responsible for coordinating the review process.
  • Reviews should include:
  • Verification that all procedures comply with federal requirements
  • Assessment of the accuracy and clarity of all student notifications, forms, and documentation procedures
  • Confirmation that training, internal controls, and record retention practices are current and effective
  • Any required changes must be documented and approved by appropriate institutional leadership.

3. Communication of Updates

  • All updates to the R2T4 policy must be communicated to:
    • Financial Aid & Scholarships staff (through training sessions or written communications)
    • Students, as necessary, via updated consumer information materials (handbooks, website, or financial aid packets)
  • Staff must acknowledge receipt and understanding of any substantive changes.

4. Documentation of Review

  • Maintain records of each review, including:
    • Date of review
    • Reviewer(s) and approver(s)
    • Summary of changes made (if any)
    • Evidence of staff training or communication regarding updates
  • Documentation ensures audit readiness and provides institutional accountability.