Federal consumer information, please see the following link:  https://fsapartners.ed.gov/sites/default/files/2024-11/consumerinfoataglance2025.docx,

 

RETURN OF TITLE IV FUNDS (R2T4) POLICY;

Federal regulations require the use of a formula established by the U.S. Department of Education, titled Return to Title IV (R2T4) to determine the amount of federal financial aid a student has earned as of the student’s withdrawal date. Students receiving Title IV Financial Aid, Federal Grants and/or Federal Student Loans that withdraw from the Institution in the first 60.01% of a payment period are subject to the R2T4 requirement. A student is considered to have earned all of their financial aid if they complete more than 60% of the days in the payment period.

 

If the student completes 60% or less of the quarter, then the Financial Aid Department must apply the formula:

 

• Number of Days Attended / Length of Quarter = % of Aid Student Earned

 

The unearned portion of the Title IV funds awarded to the student must be returned to the Federal source. The Institution must perform this calculation within 30 days of determining the student has withdrawn and then return the funds within 15 days after performing the calculation. In total, the Institution must return all funds no later than 45 days after the date of the determination of the date of the student's withdrawal. The calculation of the return of these funds may result in the student owing a balance to the Institution and/or the Department of Education.

 

Note that the institutional refund of tuition and fees is a separate calculation performed by the Director of Financial Aid.

 

Withdrawal Determination for Return to Title IV:

The return to Title IV policy applies to students who discontinue enrollment in all classes on or after the first day of the quarter. Student inquiries regarding potential withdrawal are directed to the Registrar’s Department. The withdrawal date for students is also determined by the Registrar’s Department. Students complete a withdrawal form that is used to determine the date of withdrawal. Once the withdrawal date is determined, communication is sent with the student status change to Financial Aid Department and Student Accounting Department. The student status change form is used by the Financial Aid Director to perform the return to Title IV calculation.  

 

Unofficial Withdrawal:

The Director of Financial Aid reviews posted grades at the end of every Quarter. If a student receives all non-passing grades (F’s), they may be subject to the R2T4 calculation. If a student “earned” at least one of the F’s grades (they participated in class and received the F for poor performance), then the R2T4 calculation is not required. However, if the student failed all classes because they stopped attending at some point in the quarter, then an R2T4 calculation is required based on the last documented date of attendance. The Registrar’s Department issues a Change of Status Form to campus Departments and the Financial Aid Department will use the form to determine last date of an academic related activity (i.e. documented attendance in class, submission of a homework assignment, initiating contact with a faculty member to ask a question about the academic subject studied in the course, or the taking of an exam). In this case, the last date of the academic related activity is used to determine the unofficial withdrawal date. If the last date of the academic related activity is after the 60% date of the quarter, no adjustment is required. The Financial Aid Department will perform the R2T4 calculation. 

 

Unofficial withdrawals are determined within 30 days of the end of quarter, and the return to Title IV calculation within 30 days after that.

 

 

R2T4 calculation steps:

1. The percentage of a payment period completed is calculated by the number of days enrolled up to the withdrawal date, divided by the total days in the payment period. The academic calendar is used by the Director of Financial Aid to determine the total days in the length of quarter (any cessation of attendance such as a holiday or campus closure is not counted as part of the days in the quarter.) This percentage is also the percentage of aid earned.

 

1. The Director of Financial Aid prepares a refund calculation worksheet. The Federal Return to Title IV  Refund Calculation Worksheet (R2T4) is used to verify the calculation.

 

1. The Director of Financial Aid uses the dates on the Change of Status Form to perform the R2T4 calculation. The resulting R2T4 calculation form shows the percentage of earned federal aid, the amount of earned federal aid, and the amount of unearned federal aid.

 

1. The R2T4 calculation is set for transmission to return the unearned Title IV funds. Other financial aid resources are adjusted at this time according to the refund calculation worksheet. Any refund and/or repayment of outside scholarships is determined by the donor.

 

1. Title IV returns are returned in the following order:

   1. Unsubsidized Federal Direct Loans

   2. Subsidized Federal Direct Loans

   3. Federal Parent (PLUS) Loans

   4. Federal Pell Grants

   5. Veterans Administration Grant

   6. New York State TAP Grant

   7. Access VR Funding

 

Earned vs Unearned Aid:

The calculation of Title IV funds earned is equal to the percentage of the payment period the student completed. The percentage of the payment period completed is calculated by dividing the total number of calendar days completed by the total number of calendar days in the payment period. The percentage of Title IV assistance to which the student is entitled or earned is equal to this completed percentage up to 60%. If the withdrawal occurs after the 60% point, the percentage is equal to 100%. The amount of aid the student earned is calculated by multiplying the percentage of the length of quarter the student completed by the total amount of Title IV aid disbursed (and could have been disbursed) to the student.

 

The calculation of Title IV funds to be returned is based on the percentage of unearned Title IV aid. The percentage of unearned aid is calculated by subtracting the earned aid percentage from 100%. The amount of aid the student has not earned is calculated by multiplying the percent of unearned aid by the total amount of Title IV aid disbursed.

 

If a student earned less aid than was disbursed, the Institution and/or the student may be required to return a portion of the funds. The student has up to 45 days from the time the return to Title IV calculation was made to repay the funds in order to retain Title IV eligibility. If a student earned more aid than was disbursed, the Institution would owe the student a post-withdrawal disbursement.

 

Post-withdrawal disbursement:

Students may be eligible for a late or post-withdrawal disbursement if they have accepted aid that did not disburse at the time of withdrawal. If eligible, the Financial Aid Department will send notification of the action required to either accept or decline a portion, or all, of the late disbursement within 30 days of the date of the Institution's determination that the student withdrew. The student or parent has 14 days to respond instructing the Institution to make a post-withdrawal disbursement. If the student or parent does not respond within the 14-day timeframe, the Institution may make the late disbursement upon request at a later date. The student is notified in writing with the outcome of the late request. Post-withdrawal disbursements cannot be made after 180 days of the date of determination that a student withdrew for loans and no later than 45 days for grants. A post-withdrawal disbursement would be made from available grant funds before available loan funds.

 

Grant Funds:

The Institution may automatically use all or a portion of a student’s post-withdrawal disbursement of grant funds for tuition, fee, and room and board charges (as contracted or billed by the Institution). The Institution would need the students’ permission to use the post-withdrawal grant disbursement for all other institutional charges. The Institution would disburse any amount of a post-withdrawal disbursement of grant funds that is not credited to the student’s account and would make the disbursement as soon as possible but no later than 45 days after the date of determination that the student withdrew.

 

Loan Funds:

The Institution requires confirmation from a student, or parent for a Direct Parent PLUS Loan, before making any disbursement of loan funds for a post-withdrawal disbursement.  The notification, provided within 30 days of the date of the determination that a student has withdrawn, includes the information necessary to make an informed decision as to whether the student or parent would like to accept any disbursement of loan funds.

 

If the student, or parent for a Direct Parent PLUS Loan, does not wish to accept some or all of the loan funds that the Institution wishes to credit to the student’s account, the Institution would not disburse those funds.

If a response is not received from the student or parent within the permitted time frame or the student declines the funds, the Institution would return any earned funds that the school was holding to the Title IV programs. If a student or parent submits a timely response accepting all or a portion of a post-withdrawal disbursement, per the student or parent’s instructions, the Institution would disburse the loan funds within 180 days of the date of the Institution's determination that the student withdrew.

 

Overpayments:

The Institution would notify the student if a grant overpayment is due within 30 days of the date of withdrawal. The responsibility to pay unearned aid is shared by the Institution and the student. The R2T4 calculation of the amount of assistance the Institution is responsible for returning to the Title IV accounts is calculated first. The student’s repayment obligation is determined after the school’s share is calculated. The school must return the lesser of the amount of Title IV funds that the student does not earn, or the amount of institutional charges that the student incurred for the payment period or period of enrollment multiplied by the percentage of funds that was not earned. The student’s share is the difference between the total unearned aid amount and the Institution's share. The Institution's share is allocated among the Title IV programs before the student’s share. Once the student’s share is allocated, any amount owed to a grant program is reduced by half per the 50% grant protection rule. The student share of loans are repaid by the student according to the terms of the student’s promissory note.

 

The student is obligated to return any Title IV overpayment in the same order that is required for the Institution as listed above. Student grant overpayments may be resolved through one of the following: full and immediate repayment to the institution or repayment arrangements satisfactory to the school.

Students who owe overpayments as a result of withdrawal retain their eligibility for Title IV funds for a maximum of 45 days from the earlier date the school sends the student notice of the overpayment or the date the school was required to notify the student of the overpayment. The Institution notifies the student that they must repay the overpayment or make satisfactory arrangements to repay it within 30 days of determining the student’s repayment status for all or part of the Title IV grant.

 

Notification to the Student:

The Student Accounts Department notifies the student of any outstanding balance due to the Institution as a result of the adjustment to tuition, fees and other miscellaneous charges, federal Title IV aid returned based on the Return of Title IV calculation, and any returns of institutional, state, or private grants or scholarships. The student would receive an updated billing statement showing these adjustments.

 

FAFSA VERIFICATION POLICIES AND DEADLINES

 

The policy outlines the process to verify the accuracy of information submitted on the Free Application for Federal Student Aid (FAFSA). Each year roughly one-third of FAFSA applicants are selected by the U.S. Department of Education for verification. Additionally, CURE’s Financial Aid Department may select students for the verification process under certain circumstances where conflicting information has presented itself.

 

Selection for Verification

Students who have been selected for verification are required to submit all appropriate and acceptable documentation. Federal verification must typically be completed prior to the end of the academic year or before the student ceases enrollment, whichever occurs first. Students, who fail to comply with verification requirements, including submitting documentation within required timelines, will not have Federal Title IV funds disbursed and may have Federal Title IV funds canceled. CURE considers the student to be the responsible party for providing information and completing the verification process.

 

CURE must verify the information provided on the FAFSA with financial documents the student provides to the Office of Financial Aid. The required documents are requested once CURE receives the FAFSA and may include, but are not limited to, a signed copy of the student federal tax return transcript(s) and the Verification Worksheet. A dependent student is required to submit a copy of their parent’s signed federal tax return transcript(s). Students may be asked to submit other documents as needed to complete the verification process. Students and their families who have used the IRS Data Retrieval Process and the Central Processor and have not made adjustments to the information obtained, are not required to submit tax return transcript. Students or their parents who have filed under the status “married filing separately,” or have had to amend their tax returns (example 1040X) are not eligible for the IRS Data Retrieval Process and must submit a signed copy of 1040 as well as the 1040x.

 

Deadlines and Consequences of Non-Compliance

The Financial Aid Office will not proceed with the student aid application until all required documents are returned and the verification process is complete. Any correction(s) made to your FAFSA may cause changes to your financial aid account including award amounts.

 

Federal regulations prohibit origination of federal loans after the end of the enrollment period. Loan applicants must complete all verification requirements at least one month before the end of the enrollment period to ensure sufficient time for the Office of Financial Aid staff to complete the verification process, loan award, and loan origination. The applicant must meet other loan-related requirements before origination of a federal loan.

 

If a student is requesting an income adjustment to the FAFSA through the Professional Judgment petition, the verification process must be completed first. Student’s displaying a special circumstance will be evaluated on a case-by-case basis by using professional judgment. If the financial aid counselor identifies any conflicting information on the FAFSA, the counselor reserves the right to request additional documentation.

The student is required to complete verification (if selected) to receive financial aid. If the student or parent refuses to complete the verification process, no aid will be awarded. The student is responsible for monitoring their student account for notification of further documents needed. The student is also responsible for submitting documents by the deadline for timely packaging. No changes to the cost of attendance may be made before the completion of verification, if selected, and the Financial Aid Office cannot exercise professional judgment until the process is completed.

 

If it is determined that a student has received funds which he or she was not eligible to receive, the student must repay the total amount. If a repayment is not made, the overpayment must be referred to the U.S. Department of Education and the Student Accounts Office.

 

General Procedures:

Files that are selected for verification by the Department of Education will be verified using standard verification regulations including:

• Adjusted gross income

• U.S. income tax paid

• Untaxed portions of IRA distributions

• Untaxed portions of pensions

• IRA deductions and payments

• Tax-exempt interest income

• Education credits

• Household size

• Number in college

• Number in college counselors can select students for verification for any item needed to resolve conflicting information

• Students are notified in person or by email with required verification items listed above

• Financial Aid staff review student files for conflicting information

 

Applicant Correction and Notification Procedures

Students selected for verification by the federal processor receive initial notification on their Student Aid Reports (SAR). CURE sends email notification to all selected aid applicants attaching the appropriate Verification Worksheet to the email, and identifying other documentation requirements such as the IRS Tax Return Transcript. CURE activates aid applications and the verification process only for admitted, matriculated, and continuing students.

• CURE utilizes a third party servicer to electronically submit all verified documentation to the Central Processor (CPS) for correction to FAFSA data resulting from the verification process. CPS will then send notification of these changes to the student as notification of these corrections. When it is returned, the Financial Aid staff reviews the corrections and completes award, if possible.

• When the student is awarded aid, he/she will receive an award email.

• If changes were made to the transferred information or if the institution has reason to believe that the information transferred is inaccurate, the applicant must provide other acceptable documentation as required. If a file is not selected for verification and there are no conflicts or issues to resolve, the files are awarded aid.

 

To avoid a delay in the processing of federal student aid:

• Be aware that additional documents may be requested to resolve any potential conflicting information.

• The verification worksheet must be signed by all applicable parties.

• If there are discrepancies found between the FAFSA and the documentation submitted, additional documents could be requested.

 

Potential Fraud and Falsified Information

As required by federal law and regulation, CURE will promptly report cases of suspected potential fraud and falsified information related to federal student aid programs to the Inspector General of the U.S. Department of Education. The Director of Financial Aid will review these cases and may seek the advice of CURE’s legal counsel, before filing the report with the Inspector General.

 

Want more information about Verification?

• Verification regulations 34 CFR 668.51–61

• https://studentaid.gov/apply-for-aid/fafsa/review-and-correct#provide-required-verification

• 2025-2026 Federal Student Aid Handbook

• 2026-2027 Federal Student Aid Handbook

 

NSLDS DISCLOSURE

The National Student Loan Data System (NSLDS) is the U.S. Department of Education’s central database for student financial aid records. Schools are required to certify enrollment for ALL students who are attending classes. NSLDS will include all undergraduate Title IV aid recipients enrolled at CURE, including students who have received Title IV aid at a school other than CURE. 

 

Federal loans disbursed to students or parents will be submitted to NSLDS and will be accessible by guaranty agencies, lenders, and institutions determined to be authorized users of the data system. Student and parent borrowers can track and manage their federal student loans and grants online at www.nslds.ed.gov. The secured site displays information on loans and grants, including amounts, outstanding balances and status. Student and parent borrowers can also find contact information for their loan servicer.

 

ENTRANCE AND EXIT LOAN COUNSELING INFORMATION

 

The Financial Aid Department is required to inform you of your rights and responsibilities as a Federal Direct Loan borrower. First time Direct Loan borrowers must complete an Entrance counseling session prior to the receipt of any loan proceeds. Prior to graduating, if a student has borrowed a Federal Direct Loan while attending CURE, they must complete a loan Exit counseling session before taking a leave of absence, withdrawing or graduating from the program. 

 

Why Is Counseling Important?

It helps a student:

• It helps a student understand their rights and responsibilities as a loan borrower

• It helps a student make the right choices by providing loan information and how to manage your educational costs

• It is a Federal requirement that all loan recipients must complete before funds are disbursed

 

Exit Counseling

Exit counseling provides important information to prepare students to repay their federal student loan(s). The following exit counseling tools are recommended for all students who have borrowed loans and are now planning to graduate or leave school.

 

Federal Direct Loan Exit Counseling

If a student has a Federal Subsidized, Unsubsidized, or Parent PLUS loan, they must complete the loan exit counseling session online with the U.S. Department of Education. Loan exit counseling explains all rights and responsibilities regarding the repayment of student loans.

 

THE CODE OF CONDUCT FOR EDUCATION LOANS

 

The Higher Education Opportunity Act of 2008 (HEOA) requires that institutions participating in the federal student loan programs develop, publish and enforce a code of conduct with respect to student loans.

 

To Whom the Policy Applies

This policy applies to all officers, employees, and agents of CURE who have responsibilities with respect to educational loans.

 

Policy Statement

CURE is committed to the highest standard of ethics and conduct and therefore is bound by the Schools Code of Conduct, which requires individuals to comply with legal and regulatory requirements, and policies and procedures that apply to their particular duties.

 

The institution and its employees are banned from any revenue sharing arrangements with lenders.

No employees of financial aid office and those employees who have responsibilities with respect to education loans shall solicit or accept any Gift from a lender, guarantor, or servicer of education loans.

 

Employees of the Institution’s financial aid offices and those employees who have responsibilities with respect to education loans shall not accept from a lender or affiliate or any lender any fee, payment, or other financial benefit as compensation for any type of consulting arrangement or other contract to provide services to a lender or on behalf of a lender relating to education loans.

 

The Institution will not, for any first-time borrower, assign through award packaging or other methods, a borrower's private loans to a particular lender; or refuse to certify, or delay certification of, any loans based on the borrower's selection of a particular lender or guaranty agency.

 

The Institution shall not request or accept from any lender any offer of funds for private loans, including funds for an opportunity pool loan, to students in exchange for providing concessions or promises to the lender for a specific number of federal loans made, insured, or guaranteed, a specified loan volume, or a preferred lender arrangement.

 

The Institution shall not request or accept from any lender any assistance with call center staffing or financial aid office staffing (there are exceptions such as professional development training; providing counseling materials-debt management materials, etc. provided that the lender is disclosed on the materials; short term nonrecurring assistance during emergencies).

Employees of the Institution's financial aid offices and those employees who have responsibilities with respect to education loans and who serve on an advisory board, commission, or group established by a lender, guarantor, or group of lenders of guarantors shall be prohibited from receiving anything of value from the lender, guarantor, or group of lender or guarantors, except that the employee may be reimbursed from reasonable expenses incurred in serving on such advisory board, commission, or group.

 

Definitions

For the purpose of this policy, the term below has the following definition:

Gift: Any gratuity, favor, discount, entertainment, hospitality, loan or other item having a monetary value of more than a de minimus amount, and including a Gift of services, transportation, lodging, or meals, whether in kind, by purchase of a ticket, payment in advance or reimbursement. 

 

Gifts do not include: standard material activities or programs related to a loan, default aversion/prevention, or financial literacy (e.g., workshops, training); food, refreshments, training or informational material furnished to an employee of an institution as an integral part of a training session designed to improve the service of a lender, guarantor or servicer of educational loans to the institution, if the training contributes to the professional development of the employee; loan benefits to a student employee if they are comparable to those provided to all students at the institution; entrance and exit counseling services provided to borrowers to meet the requirements of the HEA provided that the institution retains control of the counseling and the counseling is not used to promote the lenders products; or philanthropic contributions to the institution by the lender.

 

Responsibilities

All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. Institution supervisors and employees with student oversight duties are responsible for promoting the understanding of this policy and for taking appropriate steps to help ensure and enforce compliance with it.

 

Consequences for Violating this Policy

Failure to comply with this and related policies is subject to disciplinary action, up to and including suspension without pay, or termination of employment or association with the Institution, in accordance with applicable (e.g., staff, faculty, student) disciplinary procedures.

 

Related Information

CURE is a community in which employees are encouraged to share workplace concerns with Institution leadership.