Return of Title IV Funds Policy


Federal regulations require Title IV financial aid funds to be awarded under the assumption that a student will attend the College for the entire period in which federal assistance was awarded. However, in the event a student withdraws from all courses for any reason, including medical withdrawals or stops attending class, the College is required to determine if the student has fully earned the awarded Title IV aid. The return of funds is based upon the premise that students earn their financial aid in proportion to the amount of time in which they are enrolled. A pro-rated schedule is used to determine the amount of federal student aid funds he/she will have “earned” at the time of the withdrawal and return the “unearned” disbursed funds to the appropriate federal program. 


This policy applies to all students receiving financial aid at Columbia College.


All undergraduate and graduate students who receive Title IV aid and withdraw prior to the end date of a payment period will be reviewed to determine whether unearned Title IV aid must be returned.  The term “Title IV aid” refers to the following Federal financial aid programs: Unsubsidized Federal Direct loans, Subsidized Federal Direct loans, Federal PLUS (Parent/Graduate) loans, Federal Pell Grants, Iraq and Afghanistan Service Grant (IASG), and Federal SEOG (Supplemental Educational Opportunity Grant).

In order to determine whether a student’s unearned Title IV aid must be returned, as an attendance-taking institution, Columbia College must determine the student’s withdrawal date.  The College considers students to have withdrawn as follows:

  • Students who cease attendance from all of their courses eligible for Title IV aid will be considered to have withdrawn.
  • A student is considered to have withdrawn if the student does not complete all the days in the payment period.
  • The withdrawal date is always the last date of attendance at an academically-related activity by a student as recorded by instructors.

For programs offered in modules: 

Students whose program of study or course work does not span the entire length of the payment period are considered to be enrolled in courses offered in modules. Students enrolled in modules are considered withdrawn if they do not complete all of the scheduled days in a module that was used to determine the student’s eligibility for federal aid. Students are not considered withdrawn if:

  • The student successfully completes one module or a combination of modules that contain at least 49% of days within the payment period. Successful completion is defined as earning a letter grade of A, B, C, D, or S;
  • The student successfully completes coursework that represents half time enrollment. Six hours in a payment period is considered half time enrollment at Columbia College. Successful completion is defined as earning a letter grade of A, B, C, D, or S;
  • The student provides written confirmation of attendance of their intent to return to a later module within the payment period.

Students who meet at least one of the above criteria will be granted a R2T4 exemption and no adjustments to their federal aid will occur.

The College allows students to provide written confirmation on the withdrawal form at the time of withdrawal that he or she will attend a module that begins later in the same payment period. A student is not considered to have withdrawn if the College obtains a written confirmation on the College's withdrawal form email, or written by the student from the student at the time of the withdrawal. A student can also submit written confirmation close to the date of the withdrawal.

The College considers a student who provided written confirmation but does not return as withdrawn if he or she does not return as scheduled to a future module with the same payment period.

The College allows students to return to a module within the same payment period who did not confirm future enrollment in that same payment period. The student is treated as if he or she did not cease attendance. The Return of Title IV Funds calculation will be reversed.

The College determines a student's earned and unearned Title IV aid based on a required calculation that determines the percentage of the payment period completed by the student. The percentage of the period that the student remained enrolled is derived by dividing the number of days the student attended by the number of days in the period. Calendar days (including weekends) are used, but breaks of at least 5 days are excluded from both the numerator and denominator.

Determining Earned Aid

Until a student has passed the 60% point of a payment period, only a portion of the student’s aid has been earned. A student who remains enrolled beyond the 60% point is considered to have earned all awarded aid.  All students who withdraw, including those who remain enrolled beyond the 60% point, will be reviewed to determine whether unearned Title IV aid must be returned or whether post-withdrawal disbursements of Title IV aid are due. 

If the total amount of Title IV aid that a student earned is greater than the total amount of Title IV aid that was disbursed to the student (or on behalf of the student in the case of a PLUS loan), the difference between these amounts will be treated as a post-withdrawal disbursement.  A post-withdrawal grant disbursement payment will be made to the student’s account, and a notification sent by email.

A post-withdrawal of loan eligibility will be communicated to the student via email. Students must accept the loan via the electronic award letter and notify the College in writing of their interest in receiving the loan within 14 days of the notification. Once the College receives both acceptances, the loan funds will disburse to the students account. Responding after 14 days or not at all will result in forfeiture of the student’s loans for the period of enrollment.

Earned aid is not related in any way to institutional charges. The College’s refund policy and Return of Title IV Funds procedures are independent of one another. A student who withdraws from a course may be required to return unearned aid and still owe the College for the course. For more information on the Columbia College withdrawal and institutional charges’ policies, please consult the Columbia College catalog. The Financial Aid Office can assist you in calculating the amount you may be required to pay back to Columbia College. Please contact the Financial Aid Office for more information. 

The responsibility to repay unearned Title IV aid is shared by Columbia College and the student. For example, the calculation may require Columbia College to return a portion of Federal funds to the Federal Title IV programs. In addition, the student may also be required to return funds based on the calculation. A student returns funds to the Federal Stafford loan programs based on the terms and conditions of the promissory note of the loan. A student who receives a Federal Pell Grant may be required to repay 50% of the funds received.

The return of Federal aid is in the following order: Unsubsidized Federal Direct loans, Subsidized Federal Direct loans, Federal PLUS (Parent/Graduate) loans, Federal Pell Grants, Iraq and Afghanistan Service Grant (IASG), and Federal SEOG (Supplemental Educational Opportunity Grant).

How to Handle an Overpayment

Students who owe funds to a grant program are required to make payment of those funds within 45 days of being notified in writing via CougarMail that they owe this overpayment. During the 45 day period students will remain eligible for Title IV funds. If no positive action is taken by the student within 45 days of being notified, Columbia College will notify the U.S. Department of Education of the student’s overpayment situation. The student will no longer be eligible for Title IV funds until they enter into a satisfactory repayment agreement with the U.S. Department of Education.

During the 45-day period, the student can make full payment to Columbia College of the overpayment. The College will forward the payment to the U.S. Department of Education and the student will remain eligible for Title IV funds. Please make check payable to Columbia College, Attn: Business Office. Our mailing address is Columbia College, 1001 Rogers Street, Columbia, MO 65216

If a student is unable to pay their overpayment in full, they can set up a repayment plan with the U.S. Department of Education. Before doing this, please contact the Columbia College Financial Aid Office. You will need to make sure we have referred your situation to the U.S. Department of Education before any repayment plan can be set up.  Additional information is available from the Federal Student Aid Information Center.

Pell Recalculation Policy

The federal government requires all colleges to set Pell grant recalculation date(s) for every semester. The policy of Columbia College is to review/recalculate Pell grant eligibility after the add/drop period of each module in a semester. A Pell grant may be reduced or increased based on changes in enrollment.

For example, if a student is registered for courses in both the first and second modules of a semester, Pell grant eligibility will be reviewed at the end of the second module add/drop week. If the student’s enrollment has changed, the amount of Pell grant will be adjusted accordingly.

If a student is enrolled in full semester courses only, eligibility will be reviewed (and possibly recalculated) at the end of the semester add/drop period. If that student later adds a course in the second module of the semester, eligibility will be reviewed again at the end of the add/drop week of the second module.

Federal regulations also require the College to recalculate Pell grant eligibility when a student fails to attend any course used to award a Pell grant.


For questions about Return of Title IV Funds calculations, the overpayment policy, or Pell recalculation please contact the Financial Aid Office,

Related Policies: Attendance and Withdrawals

Withdrawals and attendance are a critical part of determining if a student will be federally required to be reviewed for a return of federal aid. Students who attend their courses and do not withdraw are not subject to the return of funds process. Students who do not attend courses may be academically withdrawn for non-attendance and may be required to return Title IV aid.   Attendance is considered more than logging into an online course or physically attending an in-seat course. The specific criteria for attendance is outlined in the Student Attendance Policy. Withdrawals may be required in the event that a student stops attendance as defined in the Student Attendance Policy. In the event that a student stops attending, an administrative withdrawal for non-attendance may be processed.

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