[Oasfaa] FW: Use of Scheduled hours in RT4 calculation. Question from Oct 24 workshop in OKC

[Mc Conahay, Pamela K.]

 Forwarded to OASFAA-L at request of Kevin Campbell:   



Greetings: 

On October 24, 2006, Kevin Campbell and Dave Elliott, Training Officers
with Federal Student Aid, conducted a HERA workshop at Francis Tuttle
Technology Center.

Part of the workshop dealt with the HERA issue of only using scheduled
clock hours when calculating a Return of Title IV Calculation.  This
provision was part of HERA and replaced the prior process which was to
determine if scheduled clock hours would be used or actual clock hours
would be used.   HERA mandates that only scheduled hours are to be used
when calculating a RT4.

This question was raised: 

If scheduled hours are used when calculating what percentage of the
payment period or period of enrollment has been completed, may a school
count the scheduled clock hours after the last date of attendance by the
student but prior to the determination that the student has withdrawn?

We consulted with ED's policymakers and have determined that scheduled
clock hours after the student's last date of attendance do not count as
hours in the RT4 calculation at a school required to take attendance by
an outside entity.

For example, 

Student begins program on Sept 1 
Student's last date of attendance is Sept 30 
Student completed 100 hours during this time. 
Student was scheduled to complete 120 hours during this time. 
Student withdraws, or school determines that the student has withdrawn
on Oct 4. 

The 120 scheduled hours, between the first and last dates of attendance,
would be used in calculating a RT4 calculation.  If it is a 450 clock
hour payment period, the fraction would be 120/450.

The 100 completed clock hours would not be used in the RT4 calculation
because HERA mandates the use of scheduled clock hours.

The scheduled clock hours between the last date of attendance and the
student's withdrawal or the school's determination of the student's
withdrawal  do not count and are not included in the RT4 calculation.

If there any questions, please feel free to contact Kevin Campbell. 

Kevin Campbell 
Training Officer 
Region VI 
Dallas, Texas 
214-661-9488 
kevin.campbell at ed.gov 

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