SP 4-20c – Return of Title IV Funds

Colorado Community College System / System Procedure

SP 4-20c

APPROVED: May 11, 2011
EFFECTIVE: May 11, 2011
REVISED: April 12, 2012
REVISED: August 24, 2016

REFERENCES: 34 CFR 668.22 Treatment of Title IV funds when a student withdraws; Federal Student Aid Handbook 2014-2015, Volume 5- Overawards, Overpayments & Withdrawal Calculations, Chapter 2- Withdrawals and Return of Title Funds.


/ Nancy J. McCallin /
Nancy J McCallin, Ph.D.
System President


This procedure applies to all Colorado Community College System (CCCS) Colleges.


This procedure applies only to the Return of Title IV requirements established by the federal government. The return of funds requirement is a complex process involving a great deal of interoffice cooperation. This procedure is applied to thirteen Colleges that make up CCCS, each College of which may have slightly varying internal processes and structure based upon organizational structure.


Process Overview & Applicability

Title IV funds are awarded to a student under the assumption that the student will attend courses for the entire enrollment period for which the assistance is awarded. Students who do attend and successfully complete the entire enrollment period, are assumed to have ‘earned’ 100% of the Title IV funding disbursed. Schools are required to perform a Return of Title IV calculation for Title IV eligible students who do not successfully complete the entire enrollment period due to withdrawal (official or unofficial). If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned. If the amount disbursed to the student is less than the amount 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 received.

  1. The Return of Title IV calculations are required when a student has dropped, failed, received an unsatisfactory grade (U/D, U/F) or withdrawn, officially or unofficially, from any enrolled course during a period of enrollment at the College. Students who fail to complete some courses, but not all enrolled courses, may be included in the Return of Title IV calculations. Title IV funds to be included in the calculation are as follows: Federal Pell Grant, Federal Supplemental Educational Opportunity Grant, Iraq and Afghanistan Service Grants, Federal Direct Stafford Loan (subsidized and unsubsidized), Federal PLUS loan, and Federal Perkins loans. Note:  Federal Work Study funds are not included in the calculation
  2. CCCS procedure does not require its Colleges to take attendance as a general rule. 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;
  • The College itself has a requirement that its instructors take attendance; or
  • The 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 a portion of that program.

Therefore, all CCCS Colleges will, as a general rule, use the standard 50% of the term as the last date of attendance (LDA) unless an actual date can be documented by the College. In such cases, that date will be the last date of attendance for the Return of Title IV calculations. If the outside entity has a requirement for attendance for a sub-group of students, then that sub-group of students is bound by the “College required to take attendance” rules.

Establishing a Withdrawal Date

When a student withdraws from a course or ceases to attend, they establish a withdrawal date at that time.

  1. Official Withdrawals: The withdrawal date is the date the student completes the College withdrawal process. When all courses receive a ‘W’, the withdrawal date is considered the date of initiation by the student or school as in the case of cancelled courses or student appeals.
  2. Unofficial Withdrawals: The last date of attendance for an unofficial withdrawal is the documented date recorded by the College or, if no date is available, the midpoint of the student’s term of enrollment. The last date of attendance is the last date a student participated in an academically related activity.
  3. A student is considered to have withdrawn from a payment period or period of enrollment if within that same payment period or period of enrollment the following occurs: For a program that is measured in credit hours, the student does not complete all the days the student was scheduled to complete; For a non-term or nonstandard-term program, the student is not scheduled to begin another course for more than 45 calendar days after the end of the module the student ceased attending.
  4. Withdrawal Dates for Courses Offered In Modules: If a student is enrolled in at least one module course, they are considered a module student and thus the following conditions apply. Colleges will be able to determine whether a student enrolled in a module(s) is a withdrawal by asking the following questions: After beginning attendance in the payment period or period of enrollment, did the student cease to attend or fail to begin attendance in a course they were scheduled to attend? If the answer is no, this is not a withdrawal. If the an­swer is yes, go to question 2. When the student ceased to attend 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, this is not a withdrawal; however other regulatory provisions concerning recalculation may apply. If the answer is no, go to question 3. Did the student confirm attendance in a course in a module beginning later in the period (for non-term and nonstandard-term programs, this must be no later than 45 calendar days after the end of the module the student ceased attending)? If the answer is yes, this is not a withdrawal, unless the student does not return. If the answer is no, this is a withdrawal and the Return of Title IV Funds re­quirements apply.
Written Confirmation of Future Attendance:
  1. A student is not considered to have withdrawn if the College obtains written confirmation from the student close to the date that the student actually ceased attendance and before the time the College was required to return Title IV funds, offer any post-withdrawal disbursement of loan funds, or take any other action under the Return of Title IV requirements, that the student will attend a module that begins later in the same payment period or period of enrollment.
  2. A student may also reaffirm their intent to attend by registering for a future course at the time of the withdrawal.
  3. A College may not wait to perform a Return of Title IV Funds calculation to see if the student who has withdrawn and has not provided written confirmation of future attendance will return later in the payment period or period of enrollment. The College is required to undo the Return of Title IV Funds calculation if a student who withdraws from a non-term credit hour pro­gram returns to the same program at the College within 180 calendar days. The student is treated as though they did not cease attendance. Similarly, if a student withdraws from a term-based credit-hour program offered in modules during a payment period or period of enrollment and reenters prior to the end of the period, the student is eligible to receive any Title IV program funds that they were otherwise eligible to receive prior to withdrawal.
  4. If the student does not return for the future module after providing written confirmation of future attendance, a return calculation must be completed.
Time Frame for Determining a Withdrawal Date:
  1. Official withdrawals—The withdrawal date is determined within 30 days of the date of withdrawal.
  2. Unofficial withdrawals—The withdrawal date is determined within 30 days of the end of the term.
Rescinding Withdrawal:
  • A College may allow a student to rescind their official notification to withdraw by filing a written statement that they will continue to participate in academically-related activities and intends to complete the payment period or period of enrollment.
  • If the student subsequently withdraws after rescinding an intent to withdraw, the withdraw date is the date the student first provided notification to the College or began the College’s withdrawal process, unless a last date of attendance or academically related activity is documented.
Extenuating Circumstances:

Students with extenuating circumstances may not be able to officially withdraw. For these students the College will use the date the College was notified that the student could no longer attend (i.e., death, hospitalization, incarceration, etc.).

Leaves of Absence:

The System Colleges do not grant any leaves of absence.

Academically Related Activity:

An academically related activity may be used by faculty to establish the last date of attendance. These include physically attending a course where there is an opportunity for direct interaction between the instructor and students, 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
  • Initiating contact with a faculty member to ask a question about the academic subject studied in the course.

The College is to exclude those activities where the student is not academically engaged such as:

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

For students enrolled in a distance education context, logging in is not sufficient, by itself, to demonstrate academic attendance by the student. A College must demonstrate that a student has participated.

Calculating Return of Title IV

After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds they were scheduled to receive during the period. If a student withdraws after the 60% point-in-time, there are no unearned funds. A College must still determine whether the student is eligible for a post-withdrawal disbursement.

Post-withdrawal Disbursement

The amount of the post-withdrawal disbursement is the difference between the amount of Title IV funds disbursed and the amount earned.

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

  • Second or subsequent Direct Loan disbursements to a student who did not graduate or successfully complete the loan period.
  • Direct Loan disbursement to a first-time, first year undergraduate who withdrew before completing the first 30 days of their program at a College that is not exempt from the delayed delivery/disbursement requirement.
  • Direct Loan or Federal Perkins Loan disbursement to a borrower who has not signed the loan’s promissory note.
  • Disbursements of any Title IV funds to students for whom the College did not receive a valid Institutional Student Information Record (ISIR) or Student Aid Record (SAR) 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 Perkins Loan disbursement for a subsequent payment period to a student who withdrew from a non-term credit hour program before completing the previous payment period for which the student has been paid.

Post-withdrawal notification requirements:

  • The notification must include the information necessary to make an informed decision on whether the student or parent would like to accept the disbursement.
  • The notice must be sent within 30 calendar days after the date that the College determines the student withdrew.
  • The notice must permit the parent/student to determine which funds, if any, they wish to accept/decline.
  • The notice must also advise that if there is no response within 14 calendar days that the College is not required to make the post-withdrawal disbursement and funds will be returned to the Title IV programs.
  • If the notification is received from the student/parent within 14 days, the College must disburse loan funds within 180 days and grant funds within 45 days. If authorization is received after the 14 day deadline, the College must notify the student or parent that the disbursement will not be made and why.
Returning Unearned Funds

The College will return Title IV funds to the programs from which the student received aid during the period of enrollment as applicable, in the following order, up to the net amount disbursed from each source:

  • Unsubsidized Direct Stafford Loans
  • Subsidized Direct Stafford Loans
  • Federal Perkins Loans
  • Direct PLUS loans
  • Federal Pell Grant
  • Federal Supplemental Educational Opportunity Grants (FSEOG)

Within 45 days from the date the College determined that the student withdrew, the College will return unearned funds for which the College is responsible.

  1. Within 30 days from the date the College determined that the student withdrew, the College will offer a post-withdrawal disbursement, if applicable.
  2. A student that does not repay the grant overpayment in full to the College, or enter a repayment agreement with the College or U.S. Department of Education within the earlier of 45 days from the date the College sends a notification to the student of the overpayment, or 45 days from the date the College was required to notify the student of the overpayment will lose their eligibility for Title IV funds.
    • The letter sent to the student must inform her/him of the dollar amount owed, the method for repaying the funds, and to whom, as well as the consequences of failing to repay the funds. If the student repays the funds to the College, the financial aid office will be responsible for returning the unearned funds to the proper program.
  3. Shortly after 45 days have elapsed from the date the student was informed in writing of their repayment obligation, if the student has not repaid the overpayment in full:
    • The College will report the overpayment to National Student Loan Data System (NSLDS).
    • The College will refer the student’s overpayment to the U.S. Department of Education for collection. The referral must be on College letterhead.
    • The College must report any satisfactory payment arrangements on NSLDS and correctly change the status code within NSLDS to reflect the same.
Overaward Resolution

Individual Colleges within CCCS will have their own written procedure concerning the return of funds on behalf of a student who owes an overaward and may consider the returned funds as the student’s debt to the College. Individual Colleges may also have a written procedure requiring the student to repay to the College the portion of the overpayment which was the responsibility of, and returned by, the College.


CCCS reserves the right to change any provision or requirement of this procedure at any time and the change shall become effective immediately.