Modules and Mini-Sessions:
How to Handle Drops and Withdrawals
Submitted by Cynthia Mayberry, Manager, Texas Region

A school with standard term-based programs (semesters, trimesters, or quarters) often does creative things with some of its terms to provide students with flexible scheduling and coursework options. Many of these creative approaches include the use of modules and/or mini-sessions, particularly in the summer.

But such configurations sometimes leave the financial aid office (FAO) wondering: what does the FAO do when a student drops a class or withdraws during a module or mini-session?

Laying the groundwork
First, what are modules and mini-sessions? While not defined explicitly in ED guidance, modules and mini-sessions are generally understood as shorter periods in which a student could enroll within the bounds of a longer term. ED sheds light on the nature of modules by providing criteria that apply to them on pages 5-69 to 5-70 of the 2007-2008 Federal Student Aid Handbook. According to guidance received from ED’s Office of Postsecondary Education (OPE), in the context of the use of the term “module” on those pages, modules and mini-sessions are the same.

Second, how does a school treat modules or mini-sessions with respect to the longer term? A school has the option to treat all of its mini-sessions as individual nonstandard terms or can combine them into a single standard term (per the 2006-2007 Federal Student Aid Handbook, page 3-39). The school must be consistent for all students enrolled in the same academic program and for all Title IV purposes.

What does the FAO do when a student drops a class during a module or mini-session?
If the school treats its mini-sessions as separate nonstandard terms, an undergraduate student would have to be enrolled for 12 credit hours in a mini-session in order to be considered full time for that mini-session. Thus, if a student dropped a class in a mini-session treated as a nonstandard term, that drop would affect the enrollment status of that nonstandard term only.

If the school combines the mini-sessions into a single standard term, a student would only have to enroll for 12 credits total (in all mini-sessions combined) in order to be considered full time for that term. Thus, if a student dropped a class during a mini-session of a combined standard term, that drop would affect the enrollment status for the full combined term. If a student dropped a class for a future mini-session of a combined standard term, that drop would similarly affect the enrollment status for the full combined term.

For example: a school has a summer term with two mini-sessions, and combines the mini-sessions into a single standard term. A student is enrolled in both mini-sessions at three hours each (for a total of six hours—thus, half time). The student's school has certified a Stafford loan for the student for the full summer term. Per the Common Manual subsection 8.7.F, unless a student is subject to delayed delivery, and as long as the student is enrolled at least half time for the full term, the school may deliver the first disbursement of the student’s Stafford loan funds up to 10 days prior to the beginning of the first mini-session in which the student is enrolled. Since the student is enrolled in the first mini-session of the term, the school may deliver the student's funds up to 10 days before the first day of the first mini-session. If the school delivers the student's loan based on at least half-time enrollment at the beginning of the first mini-session of the summer term, and the student completes the first mini-session but subsequently drops the class for the second mini-session, the student is not considered withdrawn—the student is considered to have dropped from half time (6 hours) to below half time (3 hours). The school is not responsible for recovering the delivered loan funds. However, if there are any undelivered loan funds, the school cannot deliver those funds because the student is now enrolled less than half time—unless the school is able to offer those funds in a late delivery. For more information on the conditions for late delivery, see the Common Manual subsection 8.7.E.

What does the FAO do when a student withdraws from the school during a module or mini-session?
The actions that a school must take when a student withdraws from the school during a module or mini-session vary, as outlined below. The following guidance is derived from the 2007-2008 Federal Student Aid Handbook pages 5-69 to 5-71, the NASFAA publication “NASFAA Answers Summer Financial Aid Questions" (see link under “More information” below), and responses to direct inquiries sent to ED’s OPE. For the sake of simplicity, the guidance refers only to “mini-sessions,” but “modules” could be substituted in the text and the same guidance would apply.

• If a school considers its mini-sessions as separate nonstandard terms, and a student withdraws from a mini-session, the school must consider the student withdrawn for Title IV purposes, and perform the R2T4 calculation, either on a payment period or period of enrollment basis, depending on how the school chooses to complete the calculation. The school would calculate the percentage of the period completed by dividing the number of days the student attended within the mini-session by the total number of days in the payment period or period of enrollment.
  
  
• If a school considers its mini-sessions as combined into a single standard term, and a student withdraws from a mini-session, the school may or may not have to perform the R2T4 calculation.
  
  
  • If a student does not complete at least one course by the end of the term, the school must consider the student to be withdrawn for Title IV purposes and perform the R2T4 calculation. The school would calculate the percentage of the period completed by dividing the total number of days the student has attended by the total number of days in the mini-sessions that the student was scheduled to attend.
    
    
  • If a student completes a course from one mini-session but withdraws from a subsequent mini-session, the student is not considered withdrawn for Title IV purposes. The school is not required to perform the R2T4 calculation, because the student has completed at least one course by the end of the term. The student's actions represent, per the 2007-2008 Federal Student Aid Handbook page 5-21, "a change in enrollment status not a withdrawal," similar to the actions of a student who, in a fall semester not composed of mini-sessions, drops from 12 credits to 9 credits, or even from 6 credits to 3 credits. As long as the student does not drop down to 0 credits, the student is not considered withdrawn for R2T4 purposes.
    
    However, it is important to remember, as stated on pages 5-70 and 5-71 of the 2007-2008 Federal Student Aid Handbook, that because of this change in enrollment status, the school would be required to recalculate any Pell Grant award in accordance with 34 CFR 690.80(b)(2)(ii) because the student failed to begin attendance in the required number of credit hours for which the Pell grant was awarded. In addition, per Dear Colleague Letter GEN-00-24, the school would also be required to revise the student’s cost of attendance in the event institutional charges were changed as a result of the reduced enrollment and in order to eliminate living expenses for periods of non-attendance; the school would then have to recalculate the student's eligibility for any campus-based aid that had been awarded. A change in enrollment status to less than half time as a result of the failure to begin attendance in all subsequent mini-sessions would not affect the student's eligibility for any FFELP or Direct Loan Program funds previously delivered.
    
    
  • If a student withdraws from the first mini-session but the student is enrolled in—and the school has obtained confirmation from the student that the student intends to attend—a future mini-session within the term, the school is not required to consider the student withdrawn for Title IV purposes. Again, the student's actions represent "a change in enrollment status not a withdrawal" and the school does not have to perform the R2T4 calculation. For confirmation, a school may not rely upon the student's previous registration. Rather, the confirmation from the student must be obtained at the time of or after the student's withdrawal.
    
    Of course, if the student subsequently does not attend the future mini-session as intended or begins and ceases attendance prior to the end of the term (thus ensuring that the student will not complete at least one course by the end of the term), the school must consider the student withdrawn for Title IV purposes and complete the R2T4 calculation. Again, the school would calculate the percentage of the period completed by dividing the total number of days the student has attended by the total number of days in the mini-sessions that the student was scheduled to attend.

More information
For more information on how to handle mini-sessions/modules and disbursements, drops, and withdrawals, refer to the NASFAA publication "NASFAA Answers Summer Financial Aid Questions" at www.nasfaa.org/publications/2003/reg2003backup/rsummerqa060903.html, to Dear Colleague Letter GEN-00-24 at www.ifap.ed.gov/dpcletters/gen0024.html, and to the 2007-2008 Federal Student Aid Handbook pages 5-69 to 5-71. For questions on these topics, call TG customer assistance at (800) 845-6267 or send an e-mail message to cust.assist@tgslc.org.