Financial Aid Refunds

There are four sources of financial aid: federal government (e.g. Title IV funds or Veteran’s Administration educational benefits), state governments, Bethel University, and private third-party organizations (e.g., Dollars for Scholars). Financial aid is refunded in accordance with policies established by each entity. Refunds are first calculated for federal funds, then state funds, then Bethel and third-party funds.

Students who withdraw from all classes during the 100% tuition refund period are presumed to have not attended their classes. These students will receive a full refund of all their financial aid unless they complete a Supplemental Withdrawal Form (available in the Office of Student Life), documenting their attendance at each class. Upon receipt of the Supplemental Withdrawal Form, the federal financial aid refund policy will be calculated using the last date of class attendance as the official date of withdrawal. If students receive a full (100%) refund of tuition, they are ineligible for any state, institutional, or private sources of financial aid.

1. Federal (Return of Title IV Funds – R2T4) Refund Policy.

When a recipient of Title IV grant or loan assistance withdraws during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student’s withdrawal date (34 CFR 668.22(a)(1)). 

The following Title IV financial aid programs are subject to the federal Return of Title IV Funds refund calculation:  Federal Pell Grant, Iraq and Afghanistan Service Grant (IASG), TEACH Grant, Federal Supplemental Educational Opportunity Grant (FSEOG) and Federal Direct Loans.   Students retain funds earned through the Federal Work Study Program prior to withdrawing from Bethel.

Only courses that count towards program completion can be included in the R2T4 calculation when determining enrollment level and institutional costs.

If a student withdraws or is expelled from Bethel after beginning classes but before completing 60 percent of their term (or period of enrollment), the school or the student may be required to return a portion of the student’s Title IV aid for the semester.   

For students in modular courses or modular programs the following four questions are asked to determine if an R2T4 calculation is required:

1. After beginning attendance in at least one course, did the student stop attending or fail to begin attendance in a scheduled course used to determine the student’s eligibility for Title IV aid?
   2. If Yes, proceed to question 2.
   3. If No, R2T4 calculation is not required.
2. When the student stopped attending or failed to begin attendance in a scheduled course, was the student currently attending any other courses in the payment period or period of enrollment used to determine the student’s eligibility for Title IV aid?
   1. If Yes, student made a schedule change and Title IV aid must be recalculated, but a R2T4 calculation is not required.
   2. If No, proceed to question 3.
3. Does the student qualify for one of the following R2T4 Exemptions?
   1. Did the student complete all requirements for graduation?
      1. If Yes, a R2T4 calculation is not required, although it may be necessary to recalculate aid.
      2. If No, proceed to question 3b.
   2. Did the student successfully complete Title IV-eligible coursework in one module or a combination of modules that equals 49% or more of the number of countable days in the payment period or period of enrollment?
      1. If Yes, a R2T4 calculation is not required, although it may be necessary to recalculate aid.
      2. If No, proceed to question 3c.
   3. Did the student successfully complete Title IV-eligible coursework equal to or greater than what the school considers to be half-time enrollment for the payment period or period of enrollment?
      1. If Yes, a R2T4 calculation is not required, although it may be necessary to recalculate aid.
      2. If No, proceed to question 4.
   4. Did the student confirm attendance in writing for a Title IV-eligible course in a later module in the payment period or period of enrollment that begins no later than 45 calendar days after the end of the module he or she ceased attending?
      1. If Yes, a R2T4 calculation is not required unless the student fails to begin attendance in later module. It may be necessary to recalculate aid.
      2. If No, perform the R2T4 calculation. It may be necessary to first recalculate Title IV aid for courses the student never attended.

The R2T4 calculation measures the percent of the enrollment period the student completed.  This ratio (number of days attended / number of days in the enrollment period or semester) is then multiplied by the “Title IV Aid that was disbursed (or could be disbursed) to determine what percent of the Title IV Aid was earned via class attendance or participation (scheduled breaks of at least five consecutive days are excluded).  Students retain the earned portion of their Title IV Aid.  The unearned portion of aid is subject to being returned to the government, and is allocated to Title IV programs from which students received assistance in the following order:  Unsubsidized Federal Direct Stafford loans; Subsidized Federal Direct Stafford loans; Federal Direct PLUS; Federal Pell Grants; Iraq and Afghanistan Service Grants; FSEOG Program aid; TEACH Grants (34 CFR 668.22(I)).

If the R2T4 calculation results in a credit balance on the students account, the balance will be disbursed to the student no later than 14 days after the calculation of R2T4 (34 CFR §668.164(h)).

The withdrawal date is the earlier of (a) the date the student first notified Bethel of intent to withdraw, or (b) the date the student actually began the withdrawal process.  BUILD and College of Arts and Sciences students initiate the official withdrawal process in the Office of Student Life, where they can inform staff of their intent to withdraw, pick up the withdrawal forms, or schedule an appointment for an exit interview.  Notification of intent to withdraw can be done in-person or by phone (651.638.6300).  Students enrolled in Bethel Seminary, the College of Adult & Professional Studies or the Graduate School initiate the official withdrawal process with the Office of Student Success and Retention (phone 651.635.8800 or email studentaffairs@bethel.edu).

Students who do not officially withdraw, but simply stop attending classes, are considered unofficially withdrawn for the purposes of R2T4 calculations.  The withdrawal date used in the R2T4 calculation for unofficial withdrawals is (a) the last date of attendance (when available), or (b) the midpoint of the semester or period of enrollment. Students who do not successfully pass any of their courses, and do not officially withdraw, are also subject to the R2T4 calculation, unless they completed more than 60 percent of the semester (or enrollment period), as documented by their academic engagement.

If the amount of Title IV funds earned by the student is more than the amount disbursed as of the withdrawal date, the school must disburse, or offer to disburse, the difference in a “post-withdrawal disbursement.” 

Post-Withdrawal Disbursement of Title IV funds.

A post-withdrawal disbursement will first be applied to the student account.  Any resulting credit balance is handled according to the requirements for Title IV credit balances in 34 C.F.R §668.22 (a)(5) and (6) and 34 C.F.R. §668.164(j). 

• A post-withdrawal disbursement must be made from available grant funds before available loan funds.
• Post-withdrawal disbursements consisting of loan funds must be offered to the student within 30 days, allowing the student at least 14 daysto respond to accept or decline the funds. Receipt of active confirmation from the student, or parent in the case of a parent PLUS loan, is required before loan funds will be disbursed as part of a post-withdrawal disbursement.
• Within 45 days of the Date of Determination Bethel will disburse directly to the student credit balances on the student’s account.
• Within 30 days of the Date of Determination Bethel will provide a written notification to the student, or parent in the case of a parent PLUS loan, that
  1. Requests confirmation of any post-withdrawal disbursement of loan funds that the institution wishes to credit to the student's account and/or disburse to the borrower, identifying the type and amount of those loan funds and explaining that they may accept or decline some or all of those funds;
  2. Explains that if the borrower who does not confirm that a post-withdrawal disbursement of loan funds may be credited to the student's account may not receive any of those loan funds as a direct disbursement unless the institution concurs;
  3. Explains the obligation of the borrower to repay any loan funds he or she chooses to have disbursed; and
  4. Advises the borrower that no post-withdrawal disbursement of loan funds will be made if the student or parent in the case of a parent PLUS loan, does not respond within 14 days of the date that the institution sent the notification, or a later deadline set by the institution.

Within 30 days of the date the school determined a student withdrew, the school must notify the student in writing of any unearned Title IV funds the student is responsible to repay, and/or notify the student and/or parent PLUS borrower of possible post-withdrawal disbursement of loan funds.  The Direct Loan borrower(s) must confirm in writing their approval of any post-withdrawal loan disbursement.

Students have 45 days to repay a grant overpayment or enter into a satisfactory repayment agreement.  Students who fail to repay the overpayment after 45 days, or fail to enter into a satisfactory repayment agreement, will be reported to the National Student Loan Data System (NSLDS) by the school and referred to the U.S. Department of Education’s Borrower Services-Collections.

Bethel also has 45 days from the date it determined the student withdrew to return its share of unearned funds and make any post-withdrawal grant disbursements. 

2. Minnesota Office of Higher Education (MOHE) Financial Aid Refund Policy.

Bethel is required to use the MOHE financial aid refund policy when calculating refunds for the Minnesota Public Safety Officer’s Survivor Grant Program, Minnesota GI Bill, Minnesota State Grants, Minnesota ID Grant, and Minnesota SELF loans. After applying Bethel’s “billing refunds” and the “Return of Title IV Funds” refund calculations to the student’s account, a proportionate share of the state aid is refunded as defined in the Office of Higher Education Refund Calculation Worksheet (Appendix 13 of the State Grant Program Manual, http://www.ohe.state.mn.us/mPg.cfm?pageID=1538). Students who withdraw without attending classes, or withdraw during a 100% tuition refund period are not eligible for any Minnesota state financial aid. Students retain funds earned through the Minnesota State Work Study Program prior to withdrawing from Bethel.

3. Financial Aid Refunds for Institutional and Third-Party Funds.

After calculating the federal and Minnesota financial aid refund policies, Bethel reduces institutional and third-party sources of gift aid in accordance with Bethel’s Tuition and Housing Refund policy (Holds & Student Billing Policies | Bethel University). Institutional and third-party gift aid is reduced by the same percent as the student’s tuition was reduced. Private educational loans are first used to pay any remaining balance on the student’s account. If, after all refund calculations, there is a credit on the student’s account, a portion of the private loan may be refunded to the lender.

Bethel’s Tuition and Housing Refund:

• Full Refund Period: The full refund period is the eighth calendar day after the beginning of the semester. Modular courses, which begin after the first week of the semester and/or end before the final week of the semester, also have a 100 percent refund period through the eighth calendar day of the course.
• Full Refund: Students are entitled to a 100 percent refund of institutional charges and monies paid to their student accounts provided they withdraw from the course(s) before the end of the Full Refund Period.
• Pro-Rata Refund: Students who withdraw after the Full Refund Period receive a pro-rata refund of institutional charges up to and including 50% of the enrollment period. The percentage of institutional charges and financial aid retained on the student’s account is equal to the percentage of the period of enrollment that was completed.
• No Refund: Students who withdraw after the end of the pro-rata refund period are not eligible for a refund. There shall be no refund available to the student if the student withdraws after completing more than fifty (50) percent of the enrollment period.
• Fees. The Bethel Student Activity fee, course fees, science lab fees, and nursing department fees (if applicable) are refunded in full through the 100% refund period. Thereafter, there is no refund of the fees.

4. Glossary for Refund Calculations^[1]

Academically-related activity: See academic engagement.  (Effective July 1, 2021, R2T4 regulations refer to “academic engagement” rather than “academically-related activities.”)

Academic engagement (34 CFR 600.2): Active participation by a student in an instructional activity related to the student’s course of study that is defined by the institution in accordance with any applicable requirements of its State or accrediting agency. 

Academic engagement includes, but is not limited to, the following activities:

• Attending a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students;
• Submitting an academic assignment;
• Taking an assessment or an exam;
• Participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction;
• Participating in a study group, group project, or an online discussion that is assigned by the institution; or
• Interacting with an instructor about academic matters

Academic engagement does not include the following activities:

• Living in institutional housing;
• Participating in the institution’s meal plan;
• Logging into an online class or tutorial without any further participation; or
• Participating in academic counseling or advisement.

Conflicting information: Information in a student’s financial aid file that is contrary to information present elsewhere within the institution and that may affect his or her eligibility to receive Title IV aid. Conflicting information must be resolved in order for federal financial aid processing to proceed.

Countable days: Bethel uses course registration data as of the student’s withdrawal date to determine the number of days the student was scheduled to attend.  The R2T4 calculation tallies the sum of “countable days” differently in the “Successful Completion of at least 49% of Period” calculation, and the “Percent of Payment Period Completed” calculation.

• Successful Completion of at least 49% of Period. The number of countable days in the enrollment period …
  • Includes all days in all modules offered during the period;
  • Excludes…
    • scheduled breaks of five or more consecutive days, and
    • all days between modules.
  • Bethel’s interpretation of the 49% ratio calculation
    • The 49% ratio calculation only applies to modular courses. If a student completed (even unsuccessfully completed) a full-semester course, then an R2T4 calculation is not required, and the 49% ratio does not need to be completed (NASFAA slide 52)
    • Only include dates for courses that apply to program requirements
    • Both numerator and denominator exclude (a) breaks of five or more consecutive days, and (b) all days between modules
    • Numerator only includes courses that were successfully completed
    • Denominator includes all courses which (a) were used to determine financial aid eligibility AND (b) apply to program requirements.
  • Percent of the Payment Period Completed calculation (# of days completed/number of countable days scheduled to attend):
    • Only include courses that were used to determine the student’s eligibility for Title IV funds (34 CFR 668.22(I)(9)), and
    • Numerator includes the total number of days in the payment period or period of enrollment that the student has completed, and
    • Denominator includes the number of countable days the student was scheduled to attend, excluding…
      • Scheduled breaks of 5 or more consecutive days,
      • Scheduled breaks that occur after the student is no longer enrolled during the period, and
      • Scheduled breaks that, when combined with a module the student is not scheduled to attend, become 5 or more consecutive days.

Date of Determination:  The date the institution determined a student that a student withdrew from the institution. For students who begin an official withdrawal process, or provide official notification to the school of their intent to withdraw, the Date of Determination is the later of (a) the date the student began the official withdrawal process, or (b) the date of the student’s notification.  For students who do not begin the official withdrawal process, or provide notification of their intent to withdraw, the Date of Determination is the date the school became aware that the student ceased attendance.

Earned aid: A withdrawn student’s earned aid is the amount of Title IV aid he or she is entitled to, based upon the amount of the payment period or period of enrollment completed as of the date he or she withdrew. A student’s earned aid may be either disbursed or undisbursed.

Last date of attendance (LDA): The date determined by an institution that the student last participated in an academically-related activity.

Late disbursement: A disbursement of Title IV aid made to an otherwise eligible student after the date that:

• For a loan under the Federal Direct Student Loan (Direct Loan) Program, the student is no longer enrolled at the institution as at least a half-time student for the period of enrollment for which the loan was intended; or

• For offered aid under the Federal Pell Grant, Federal Supplemental Educational Opportunity Grant (FSEOG), and Teacher Education Assistance for College and Higher Education (TEACH) Grant programs, the student is no longer enrolled at the institution for the award year.

Leave of absence- LOA: Bethel University does not have a formal policy regarding leaves of absence as referenced in 34 CFR 668.21(d).  Therefore, periods of non-enrollment are treated as a withdrawal for the purpose of calculating a Return of Title IV funds refund.

Payment period: A school-determined length of time for which financial aid funds are paid to a student. For programs using academic terms (semesters, trimesters, or quarters), a payment period is equal to the term. For programs not using academic terms, schools must designate at least two payment periods within an academic year that meets all applicable regulations.

Period of enrollment: The period coinciding with one or more academic terms established by the school for which institutional charges are generally assessed, such as a semester, trimester, or quarter in weeks of instructional time; an academic year; or the length of the program of study in weeks of instructional time. Also referred to as the loan period.

Post-withdrawal disbursement: The amount of Title IV funds earned by a student that exceeds the amount disbursed at the time he or she withdrew. The school must disburse, or offer to disburse, a post-withdrawal disbursement.

Program offered in modules: An academic program in which all the courses do not span the length of the payment period or period of enrollment (34 CFR 668.22(I)).

Successful completion of course:  Student earned passing grade.  Incomplete and similar grades (no matter what they’re called) are not successful completion.  For example, clinicals, thesis, dissertations, etc., are not successfully completed when no passing grade is assigned upon completion of the module.  Failing (or unsatisfactory) grades are not successful completion.

Title IV eligible courses: Courses that count towards degree or certificate completion requirements.  Optional courses that do not count towards degree/program completion requirements and audited courses are not Title IV eligible.

Withdrawal: When a student ceases attendance in all classes for which he or she was registered for a payment period or period of enrollment.

Sample refund calculation.

Because there are several different refund policies involved in most withdrawals, students may still owe money to the school after all calculations are completed. Students considering withdrawal are encouraged to visit a financial aid counselor and simulate the financial effect of withdrawing before officially withdrawing from the university.

Suppose a student is enrolled full time and withdraws from all classes on the 10th day of a 110-day semester. The student lived on campus and had a meal plan. Sample charges and financial aid are listed in the "original" columns below. After applying all the refund calculations, this student will receive a refund of $2,750.

Institutional Charges
	Original	Refund %	Refund $	Net Charges
Tuition	$21,380	90%	($19,242)	$2,138
Room	$3,145	90%	($2,831)	$314
Class Fee (e.g., lab)	$65	0%	$0	$65
Meal Plan	$2,830	90%	$(2,547)	$283
Student Activity Fee	$85	0%	$0	$85
Total Charges	$27,505		($24,620)	$2,885
Financial Aid and Cash
	Original	Refund%	Refund $	Net Payments
Federal Stafford Loan	($2,750)	100%	$2,750	$0
Federal Pell Grant	($3,175)	78%	$2,470	($705)
Minnesota State Grant	($3,248)	89%	$2,880	($368)
Bethel Royal Merit Scholarship	($7,600)	90%	$6,840	($760)
Bethel Grant	($3,025)	90%	$2,723	($302)
Private Scholarship	($500)	0%	$0	($500)
Sub-total	($20,298)	87%	$17,663	($2,635)
Summary
	Original		Refund $	New Bill
Total Charges	$27,505		($24,620)	$2,885
Total Payments on Account	($23,298)		$17,663	($5,635)
Difference*	$4,207		($6,957)	($2,750)

_{*SOURCES:  2023-2024 Catalog, adjusted based on feedback from Mary Murray (U.S. Dept of Education, as documented in P:\Refunds\R2T4 Policy - Bethel University 20180711.docx; as well as an updated example as found in O:\Refunds\catalog calculations.xls)}

 

_{[1] Glossary copied from NASFAA U Self-Study Guide: Return of Title IV Funds, 2020, pages 99-100.  Terms modified as needed to comply with changes to federal refund regulations effective July 1, 2021 (e.g. Notice of Proposed Rulemaking (NPRM)-April 2, 2020 Federal Register; Distance Education and Innovation Final Rule-September 2, 2020 Federal Register; 34 CFR 668.22).}