A new R2T4 withdrawal exemption is eligible for early implementation, as well as a change that affects Leaves of Absence for PEPs.
By Rick Cox and Siobahn Arbogast
New regulations regarding Return to Title IV take effect July 1, 2026; two are eligible for early implementation.
The new provisions include:
- The Department of Education has codified the long-standing regulation that for attendance-taking schools, the Date of Determination must be within 14 days of the Last Day of Attendance, even if determined after the 14 days.
- For Leaves of Absence for Prison Education Programs only — a student does not have to return to the same point in the program in which they left. PEP students can return from an LOA at a different point in the program.
– Eligible for early implementation. - New withdrawal exemption.
– The following criteria to exempt a student from an R2T4 must all be met:
– The institution must treat the student as if they never attended.
– All Title IV funds disbursed, and any credit balances issued, must be returned.
– All institutional charges for the period must be refunded.
– Any remaining balance for the period must be written off or cancelled.
Eligible for early implementation.
Optional exemption can be case-by-case as long as policies and procedures specify such. - For streamlining of the Return to Title IV method for clock hour programs:
The “cumulative method” for calculating scheduled hours will no longer be used. Instead, the “payment period method” must be used.
– Schools must use payment period or period of enrollment for Return to Title IV. - Modules — a module will only be used in the denominator if the student began attendance in that module.
Rick Cox is Global’s Executive Director of Regulatory Affairs and Compliance. Siobahn Arbogast is Global’s Director of Title IV Accounting.
August 7, 2025
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