A reminder that rules for Return to Title IV and Leave of Absence in PEPs can be implemented now. Most new regulations take effect July 1, 2026, but two provisions became eligible for early implementation in February.
By Rick Cox
On January 3, 2025, the Department of Education issued a final rules Federal Register on Program Integrity and Institutional Quality. These new regulations are generally effective on July 1, 2026. However, two provisions were eligible for early implementation on or after February 3, 2025.
Below is a summary of the two provisions that are eligible for early implementation:
1. Return to Title IV is not required if:
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- A student is treated as never having begun attendance.
- The institution returns all Title IV aid for the payment period (or period of enrollment), including any credit balances provided to the student or parent.
- The institution refunds all institutional charges for that payment period (or period of enrollment).
- The institution writes off or cancels any balance owed for that payment period as a result of returning all of the Title IV aid.
Please note that this is optional. You don’t have to implement this exemption. Institutions can also do this on a case-by-case basis, depending on your institution’s policy.
Additionally, you will need to include this in your policies and procedures manual to document your decision for early implementation.
2. A student enrolled in a Prison Education Program who takes a Leave of Absence will be allowed to return to any coursework, which will not have to be the same coursework they were enrolled in at the time of the LOA, even if this is a term-based program.
You will also need to include this in your policies and procedures manual to document your decision to early implement this provision.
You can access this Federal Register here.
Rick Cox is Global’s Executive Director of Regulatory Affairs and Compliance.
March 26, 2025