PURPOSE / SCOPE:
This policy provides Idaho College of Osteopathic Medicine (ICOM) students with guidelines
pertaining to federal requirements regarding Title IV aid that a student earns during the normal course of attendance of the Idaho College of Osteopathic Medicine.
POLICY AND PROCEDURE:
The policy outlined below applies to Federal Title IV aid recipients. Title IV aid is awarded and disbursed to students with the understanding that students will attend school for the entire period for which the assistance is awarded and successfully complete their courses while progressing toward graduation. When a student does not attend for the entire period or does not successfully complete all of their coursework, the U.S. Department of Education requires institutions to determine the amount of earned and unearned Title IV aid. Title IV aid programs at ICOM covered by this policy are the Direct Unsubsidized Loan and the Direct PLUS Loan (Graduate).
The degree program offered at ICOM is offered in modules. Modular programs are subject to certain
exemptions that do not require a return of Title IV aid. Students who have successfully completed a class or classes that comprise at least half-time enrollment, have completed all of the requirements for graduation, or who have successfully completed a class or classes that comprise at least 49 percent of the days in the semester, are not subject to returns of Title IV aid.
ICOM determines the earned and unearned amounts of Title IV aid by performing a calculation using the date the student is considered to have withdrawn, as well as the days in the enrollment period. This calculation provides the amount of aid earned up through the date of withdrawal and the amount of unearned aid that is required to be returned. If student did not receive all of the funds they earned, they may be eligible for a post-withdrawal disbursement. For loans, ICOM has to get a student’s permission before disbursing loan funds.
There are two types of withdrawal recognized by ICOM that require a Return to Title IV Funds (R2T4)
calculation.
- Official Withdrawal — An official withdrawal is one where the student has provided notice or
stated their intent to cease attending school either through beginning the official withdrawal
process (submits a signed and completed form) or through official notification of their intent to
withdraw provided to any ICOM representative. The date the student starts the withdrawal
process or is withdrawn from all courses is the official withdrawal date. The withdrawal date is
used to determine the earned and unearned portions of Title IV aid. If a student is dropped or
withdrawn from some of their courses, creating a lapse in attendance between modules, the
student must inform ICOM in writing (prior to or at the time of withdrawal/drop) of their
intention to return to a later module in the same payment period/period of enrollment, in order
to not be considered an official withdrawal. If ICOM has written confirmation of future
attendance and the student fails to return, the student will be considered officially withdrawn.
The dates used in the R2T4 calculation are the same as if the student had not provided written
notice of future attendance. - Unofficial Withdrawal — An unofficial withdrawal is one where the student has not provided
notice of their intent to cease attending school. Students are unofficially withdrawn if they cease
attending at any point in the period of enrollment without providing notice to ICOM, if they
receive unsatisfactory grades in all of their courses without attending the full period of
enrollment, or otherwise did not attend to the end of the enrollment period. If ICOM determines
that a student did not provide official notice due to circumstances beyond their control (such as
serious illness, accident, grievous personal loss, etc.), ICOM uses the date associated with the
circumstance or the last date of academic activity, whichever is later. For all other students who
unofficially withdraw, the withdrawal date is the last date the student participated in an
academically related activity (as reported by their instructors).
When ICOM determines that a student has either officially or unofficially withdrawn, federal law/regulation outlines the required steps to determine the amount of aid that has been earned and not earned. The amount of aid earned is determined on a pro rata basis. For example, if a student completed 40% of the payment period, they earned 40% of the aid they were eligible to receive. The pro rata schedule is used up through the 60% point in each period of enrollment. After the 60% point in the period of enrollment, a student has earned 100% of the Title IV funds they were scheduled to receive during the period. The Office of Financial Aid uses the following steps to determine the amount of earned and unearned aid:
- Determine if the student withdrew and is subject to R2T4 (did they have federal aid, did
they begin attendance, do they qualify for an exemption) - Determine the student’s official withdrawal date
- If no official withdrawal date, determine the student’s unofficial withdrawal date following the
guidelines outlined above (either the date of the circumstance or the last date of attendance) - Determine if eligibility for aid and amounts has changed, make appropriate adjustments
- Determine if Cost of Attendance needs to be changed, make appropriate adjustments
- Determine the amount of the student’s institutional charges
- Determine the amount (if any) of Title IV aid disbursed to the student
- Determine the amount (if any) of Title IV aid that could have been disbursed, including undisbursed aid and aid the student is eligible for as a post-withdrawal disbursement. If the student is eligible for a post-withdrawal disbursement of loans, contact the student for permission to receive/disburse loans
- Calculate the percentage of the payment period completed
- Calculate the amount of the student’s earned and unearned Title IV aid
- Calculate the amount of Title IV aid ICOM must return
- Calculate the amount of Title IV aid (loans) the student must return*
- Notify the student of the determinations and result of the calculations used to determine the amount of Title IV aid earned and required to be returned
- Notify the student of the resulting balance owed to ICOM and/or the U.S. Department of
Education
When returning Title IV funds to the U.S. Department of Education, ICOM follows the specific order of aid to return outlined within federal regulations and returns the Unsubsidized Direct Loan funds determined by the calculation first, then reviews and returns any unearned portion of the Direct PLUS Loan (Graduate).
Important Notes:
Amounts required to be returned to the U.S. Department of Education by ICOM become debts immediately due and payable to ICOM. The debt resulting from the R2T4 calculation will be billed directly to the student and must be paid to ICOM. The student MUST make prompt payment or payment arrangements to satisfy the debt owed to ICOM. ICOM reserves the right to refer the debt to a collection agency.
Amounts returned by ICOM to the U.S. Department of Education on the student’s behalf are not negotiable, they are based on a federally regulated calculation of earned aid. ICOM must return the amount of unearned Title IV funds as soon as possible, but no later than 45 days after the date of the institution’s determination of a student’s withdrawal.
* If the student owes an amount beyond the amount returned by ICOM to the U.S. Department of Education, the student must repay the loan funds in accordance with the terms of the promissory note. The student is not required to repay any loan funds immediately but should make scheduled payments to the holder of the loan.
These procedures along with the federal law/regulations they are based on are subject to change without notice.
PRIMARY POLICY OWNER:
This policy is the responsibility of the Office of Financial Aid
APPROVAL:
Effective: 3/16/23
Last Reviewed: 2/15/24
Review Requirement: