Resource center · Title IV

R2T4 changes July 1, 2026. Here's what to do about it.

Return of Title IV is already the single most common source of program-review findings — and the clock-hour rules change on July 1, 2026. This is the plain-English explainer, a free calculator that shows the math, and a readiness checklist. No form required.

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The R2T4 calculator that shows its work

Enter a withdrawal scenario; watch every step compute, the way a program reviewer reads it.

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The short version

The method changes for clock-hour programs. The percentage of the payment period completed is tied to scheduled hours, and the cumulative method goes away.
The 14-day determination window is codified. If you take attendance, you must determine a withdrawal no later than 14 days after the last date of attendance.
Reconstruction is the risk. Schools that retrofit the process under deadline are exactly where findings are created.

Are you R2T4-ready? A 6-point check

1Can you produce a withdrawal’s last date of attendance within 14 days — from a record, not a reconstruction?

2Do your clock-hour R2T4 calculations use scheduled hours in the payment period (not the cumulative method)?

3Does the attendance your teachers take feed the R2T4 math directly, or does it sync from a separate LMS / attendance vendor?

4Can you show the worked R2T4 calculation — every step — to a program reviewer on demand?

5Is R2T4 computed continuously, or reconstructed in a spreadsheet the week of the audit?

6When the rule changes, do you wait on a vendor ticket — or does your platform already compute it correctly?

If you answered “no” to any of these, the seam between your systems is your exposure. ApolloSRM removes it by computing R2T4 on the same record your teachers take attendance on.

Frequently asked

What changes for R2T4 on July 1, 2026?

The Department of Education’s R2T4 final rule standardizes how clock-hour programs calculate the percentage of the payment period completed — tying it to scheduled hours within the payment period and eliminating the cumulative method. It also codifies the requirement to determine a withdrawal no later than 14 days after the last date of attendance.

Why are clock-hour programs most affected?

Clock-hour and modular programs are exactly where the calculation method changes. Schools that built their process around the cumulative method must change how they compute the percentage completed — and do it correctly from day one of the new rule.

Why is R2T4 the #1 audit finding?

Because it usually happens at the seam between systems — attendance in the LMS, the withdrawal decision in the registrar, the refund in financial aid — and gets reconstructed under deadline. The 14-day determination clock runs out, and the audit trail is a guess.

How does ApolloSRM handle it?

The attendance a teacher takes is the same attendance that drives the last date of attendance, so R2T4 is computed continuously from the live record — with every figure shown — instead of rebuilt under audit pressure. Clock-hour and credit-hour are both first-class.

This page is educational, not compliance advice; confirm requirements against the current federal regulations and the FSA Handbook.

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