Build the R2T4 file a financial aid administrator determines from — the withdrawal-date evidence, the return position per fund, the clocks — and be the desk our student-support agent hands anything touching aid to.
A student stops attending in week four and is noticed in week nine, and the file carries both dates, not one.
02
A last date comes back from faculty, and a grade-entry date is refused as an attendance fact.
Reason
03
A determination is made, and the file dates it and names the administrator who made it.
04
A bare LMS login is not academic engagement under 34 CFR 600.2, and is refused.
05
A student states the date they stopped, and it stays unsupported until a record carries it.
Decide
06
A module registered but never begun leaves the denominator, from 1 July 2026.
07
A loan post-withdrawal disbursement waits on an affirmative reply.
Out
08
A calculation deadline is quoted from ED guidance, and the file does not claim the regulation states it.
09
Execute write actions only inside the approval boundaries agreed during implementation.
→Product statement
The agent assembles the evidence and runs the clocks; a named financial aid administrator determines the withdrawal date, and the institution makes the return.
Example workflow
One withdrawal, evidence to return
AgentHuman
1Withdrawal signalledFaculty attendance record, LMS activity, a registrar drop or a bursar charge reversal
2Evidence gatheredEach attendance fact with the record it came from, its date and whether it meets academic engagement
3File assembledLast-date position and its source, calculation inputs, return positions per fund and confidence
4Controls appliedEngagement-definition checks, module-begun checks, clock arithmetic and confidence threshold
No human action required
Stages 1 to 4 run unaided, and none of them determines a withdrawal date — the agent is assembling, and the administrator lane opens at the confidence gate.
5DecisionBranches at the confidence threshold
High confidence
Goes to the financial aid administrator.
Low confidence
Adds a director-of-aid read first.
Administrator review
The file is held with its evidence, the source of each date and the confidence.
Review · Correct · Send to the director
Reviewed — the administrator determines▼
6Aid and bursar systems updatedOnly where write access and approval policy allow it
7Outcome evaluatedEvidence completeness, date corrections, return timeliness and findings raised at audit
Corrections
Every administrator correction is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Determining the withdrawal date, or the date of determination the clocks hang off.
Making the return, or moving money to the Department or a lender.
Packaging aid, or releasing a post-withdrawal disbursement.
Applying the full-refund withdrawal exemption to a student.
Automation boundaryAgent acts unaided
✓Gather attendance facts and name the record each one came from.
✓Run the clocks from the determination and show the days left.
✓Assemble the calculation inputs and the position per fund.
✓Show what the file is missing, and hold it open.
Wrong after the determination and the return already went out — on the wrong amount, or late.
Approving a leave of absence, or judging that one held.
Student status reporting — the registrar's act, and our enrollment and records agent.
Resolving conflicting information, or referring anything to the OIG.
Changes to clock, evidence or determination-control configuration.
Example output
One withdrawal, annotated
Everything the agent assembles is attached to the record it came from.
Withdrawal-file output · single studentIllustrative example
Student
Evidence line
Days to return
Rule applied
Confidence
Determination status
Term withdrawal
Last graded discussion post sits four weeks before the LMS login the report used
Day 31 of 45
34 CFR 600.2
88%
Undetermined — evidence conflict
As receivedTaken from the attendance records and the registrar drop as received — nothing on this side is the agent's.
Record usedGraded discussion postLMS activity reportRegistrar drop record
Why this flagA login with nothing after it is not academic engagement; the graded post is the fact.
ActionReviewCorrectSend to the director
What the score decidesBelow the configured threshold the file picks up a director read before the administrator sees it.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Every withdrawalFrom the attendance and registrar records
03Assembly
Assemble against the record
Draw on faculty attendance, registrar and bursar records and the module map. The rules at 34 CFR 668.22 were rewritten with a general effective date of 1 July 2026, and what moved was the evidence rather than the arithmetic.
01Approved path
Late is priced, wrong is not
Routine evidence gathering and clock arithmetic arrive already done.
02Human review
Point people at the clock
A return outside the timeframe at 34 CFR 668.173, across enough of an audit sample, is priced in an irrevocable letter of credit; a calculation error is not. And R2T4 is not the top audit finding — in each ranking ED has published, student status reporting leads it.
04Build an evidence trail
The date, the evidence it rests on and the administrator who determined stay on the file.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
A term-level attendance-evidence figure can read sound while one fund and one withdrawal type hold most of the unsupported dates. Nestack reports the gap rate by slice, not only in total.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
Unofficial withdrawals in modules
9.5%
3.7×
Review
Clock-hour second-period exits
6.9%
2.7×
Review
Direct Loan post-withdrawal cases
4.7%
1.8×
Watch
Pell-only official withdrawals
2.3%
0.9×
Normal
Bar: gap-rate lift vs. the Pell-only official-withdrawal baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
A late return ends as a test
The loop shuts when the late return is a regression case. That suite is what the next withdrawal worked is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Gap rate rises in one withdrawal type.
02Diagnose
The student who stopped attending in week four and was noticed in week nine is read back through the attendance records until the cause narrows to one.
03Improve
Any change goes out numbered, with the withdrawals that caused it attached.
04Verify
One withdrawal case still failing is enough to hold the release back.
05Learn
One case joins the suite, one line joins the student record.
Learn → DetectThe return edge. The next withdrawal is detected against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, withdrawal workflow, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Withdrawal workflow discovery and refusal boundary.
02Registrar, bursar and aid source assessment.
03Clock, evidence and calculation-input rule mapping.
04Attendance and enrolment ingestion.
05Clock arithmetic and evidence binding.
06Confidence scoring and finding routing.
07Administrator review workflow.
08Aid and bursar-system integration.
09Date and calculation cases.
10Guardrails and determination controls.
11Withdrawal-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne campus, one termProductionProduction aid and student systemsAdvancedMultiple campuses / systems
Introduced at Pilot
Evidence and clocks against your records✓✓✓
Administrator review✓✓✓
Attendance-evidence baseline✓✓✓
Introduced at Production
Reporting by fund—✓✓
Review workflow in your systems—✓✓
Approved record write-back—✓✓
Registrar-and-bursar integration—✓✓
Introduced at Advanced
Multi-programme calculation rules——✓
Multi-stage aid-office review——✓
High withdrawal volume——✓
Multi-campus return controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, withdrawal volume, review controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your attendance sources and where drops land→Attendance and enrolment ingestion, and evidence bindingWeek 1
02Representative withdrawals from a past term→Attendance-evidence baseline, date normalisation and rule bindingWeek 2
03Your calculation inputs and your module map→Clock, evidence and calculation-input rule mappingWeek 1
04Access to relevant APIs, feeds or exports→Registrar, bursar and aid-source review, then integration setupWeek 2
05Returns you would not want audited→Clock cases and the evaluation suiteWeek 4
06What no determination may assume→Confidence scoring, finding routing, guardrails and determination controlsWeek 3
07The named financial aid administrator→Administrator review workflow, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
Widths on this chart come from worked weeks, not from layout, and that is why the fifth doubles.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Withdrawal workflow discovery, rule mapping and the refusal boundaryW2Record integration and the attendance-evidence baselineW3Clock arithmetic, calculation inputs and review controlsW4Evaluation suite, clock cases and failure-mode testingW5Aid and bursar integration, a pilot term and targeted correctionsW6One term run under the financial aid administrator, then Agent Care handover
Reading the bandA bar covers only the weeks its own work is named in. The fifth-week doubling is real, not padding.
At the end of W6Once the term validates, Agent Care assumes the running agent.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Education AI agent
Build a Title IV returns agent around the administrator who determines.
Show us your attendance sources, your module map and who determines a withdrawal date. That determination belongs to one named financial aid administrator, it is dated, and every clock in 34 CFR 668.22 runs from it.
