Every month, HESC’s “Question and Answer” web feature will include the most interesting question presented to the Office of Counsel and Regulatory Compliance staff.

This month’s winning question is:

A student withdraws from school due to the impacted of military mobilization, however, the school is not made aware of the reason for the withdrawal at the time and a Return to Title IV calculation (R2T4) is performed. When the student subsequently returns to the school to reenroll the school learns the reason for the withdrawal. Should the R2T4 calculation be reversed?

No, as specified in Dear Colleague Letter Gen-03-06, even if the school knew the reason for the withdrawal it would still have been required to complete the R2T4 calculation and return any unearned aid to the appropriate program(s) under federal regulation 34 CFR 668.22.

In addition, if the refund calculation had resulted in a grant overpayment that the student would otherwise be responsible to repay and was referred to the Department for collection at the time of withdrawal, the Department should be notified to correct the reason for the overpayment to indicate “Military Mobilization”.

Questions regarding this guidance should be directed to the Office of Counsel and Regulatory Compliance at 518- 473-3986, or toll-free at 1-866-431-HESC (1-866-431-4372); press 6, or, Ask Policy@hesc.org