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FAME Regulatory Bulletin

Is it “♫ Time to Say Goodbye ♫….”? That is, is it a Student Suspension, LOA, or Withdrawal?

Determining when it is “time to say goodbye” to a student is often a situation that may cause angst.  Various ways to maintain the individual as a student are explored.  Yet, that study generates questions as a result of uncertainty in how to proceed.

There have been times when an institution has “suspended” a student from his/her enrollment in an academic program.  Such a practice, whether due to academic performance, financial matters, poor attendance, disciplinary measures, or other reason, must be carefully considered.  There are several points related to Title IV Federal Student Aid to ponder when deliberating the possible suspension of a student.

  1. Do current regulations allow for the concept of a “suspension?”

In general, Title IV regulations do not acknowledge the idea of a “suspension.[1]”  A student is either enrolled as a regular student, on an approved leave of absence (LOA), or the student is withdrawn or graduated.  (Note that ED has no enrollment reporting status codes for a “suspension.”[2])  The most recent guidance we have received from the U.S. Department of Education (ED) states that “there is no formal policy that allows exceptions to the withdrawal process due to suspensions.”

  1. Does our academic program structure allow for the possibility of an “approved LOA” as described in regulation?

It is important to remember that there are specific requirements that must be met in order for an institution to be able to offer an “approved LOA.”  As it relates to Federal Student Aid purposes, a LOA is a “temporary interruption” in a student’s program of study for a period other than during an institutionally scheduled break, although a scheduled break may occur during the time period of an LOA.[3]

While many institutions may desire to offer LOA opportunities, from a regulatory standpoint and ED guidance in the Federal Student Aid Handbook, LOAs are actually only potential options for clock hour or non-term or nonstandard term credit hour programs offered in modules.  There may be the possibility of LOAs in a term-based credit hour program if it is offered in a modular format with more than two modules per term.  (This is due to the fact that a student returning from an LOA must complete the term to be eligible to receive a second or subsequent disbursement.[4])

For the student desiring an approved LOA in a non-term or nonstandard term credit hour program offered in modules, the student must provide a written notice of intent to return within the payment period or period of enrollment, but not later than 45 days after the end of the last module he/she attended.[5]

It is rare that a term-based, credit-hour institution may offer approved LOAs.  Those term-based, credit-hour institutions that wish to consider offering approved LOAs should contact their ED School Participation Team representative to gain additional information regarding the idiosyncrasies of LOAs and meeting the specific criteria of the regulations.[6]

  1. Does a “suspension” really mean an “unapproved” LOA?

ED indirectly refers to the concept of a suspension in the Federal Student Aid Handbook, without using the lingo of “suspension.”  Rather, in ED’s discussion on the matter, it is stated that an institution may grant a student an LOA even when it does not meet the standards for it to be classified as such for Title IV purposes (“for example, for academic reasons”[7]).  Specifically, ED states with clarity that any LOA that does not meet all the requirements of an “approved LOA” is considered a withdrawal.  Naturally, this has implications on the date of determination (DOD) of the student’s withdrawal, depending upon whether the institution is one that is required to take attendance or not.

Since an unapproved LOA (in the case of a suspension) is actually a “withdrawal,” the withdrawal could not be considered an “unofficial” withdrawal because an unofficial withdrawal only occurs when a student has stopped attending or will stop attending, but has not informed the institution.  In the case of an unapproved LOA (or, suspension), the institution knows immediately that the student has stopped attending.  As such, the institution must use that withdrawal date (i.e., last date of attendance, or LDA) in the Return of Title IV Funds (R2T4) calculation.

  1. Does a withdrawal ever get undone?

There is potential for a scenario when a withdrawal may be reversed.  For example, a student that withdraws from a clock hour or non-term credit hour program, but then returns and re-enters within 180 days, would be a situation where the student’s withdrawal is treated as though he or she did not cease attendance.  In such a case, the institution would need to:

  • re-disburse aid that had been disbursed but returned under the R2T4 provisions;
  • disburse any aid not disbursed to the student which he/she would have otherwise been eligible prior to withdrawal; and,
  • cancel any overpayments assessed to the student if the student was eligible for those funds upon re-entry and they were subsequently disbursed to the student.[8]

As is so often the case, there are many considerations when deliberating the action to take in regard to a student’s situation (whether the issues are academic, attendance, financial, or whatever).  Making an accurate determination of a student’s status is critical to compliant operations.  Student suspensions must be done carefully to avoid violating regulatory guidance.  As a result, on occasion, it may be “time to say goodbye,” while still hoping the student will return and graduate.


[1] Electronic Code of Federal Regulations, Title 34:  Education, Part 668, Subpart B, §668.22 (e-CFR data is current as of September 14, 2017); U.S. Government Publishing Office.
[2] “Enrollment Statuses (Campus- and Program-Level Record), ”NSLDS Enrollment Reporting Guide (November 2016), page 22.
[3] “Approved Leave of Absence,” Withdrawals and the Return of Title IV Funds, 2017-2018 Federal Student Aid Handbook, Volume 5, page 5-10.
[4] Ibid., page 5-12.
[5] Ibid., page 5-62.
[6] Ibid., page 5-13.
[7] Ibid., page 5-15.
[8] Ibid., page 5-29.

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