SPRINGFIELD TECHNICAL COMMUNITY COLLEGE

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster AL #: 84.063 and 84.268 Award year: 2025 Criteria The Code of Federal Regulations, consisting of 2 CFR 200.303, 34 CFR 685.309, and 34 CFR 668.22(f), requires a percentage of the payment period completed to be determined in calculating the amount of Title IV funds to be returned by the institution or student when a student completely withdraws from enrollment. The total number of calendar days in a payment period includes all days within the period, except that institutionally scheduled breaks of at least five consecutive calendar days (including module programs that a student is not required to attend for five consecutive calendar days) and days in which the student was on an approved leave of absence are excluded from the total number of calendar days in a payment period. Condition During our testing of Return of Title IV (“R2T4”) Funds calculations for the College, we noted 11 of the 40 students tested had a scheduled break of 9 days improperly included in the total number of days in the payment period for the Spring term. Cause The College did not exclude the schedule break from the payment period in the R2T4 worksheet used within their student financial aid management system. Effect The R2T4 calculations used a larger payment period for calculating the percentage of payment period completed, resulting in returning excess Title IV funds. Questioned Costs $1,047 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 11 students, or 27.5% of our sample, had an improper payment period included in their R2T4 calculation. Identification as a Repeat Finding, if applicable N/A Recommendation The College should review their R2T4 policies and procedures to ensure correct payment periods are being used within the calculations. View of Responsible Officials The College agrees with the finding.

Finding number: 2025-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster AL #: 84.063 and 84.268 Award year: 2025 Criteria The Code of Federal Regulations, consisting of 2 CFR 200.303, 34 CFR 685.309, and 34 CFR 690.83(b)(2), requires that enrollment status changes for students be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Additionally, schools are required to certify enrollment at a minimum of every 60 days or every other month. Condition During our testing of NSLDS Enrollment Reporting for the College, we noted 1 of the 40 students tested had a status change received by NSLDS outside of the 60-day reporting time frame. Cause The registrar's office ran a report after a flex term in search of students with an unofficial withdrawal status. The report omitted a classification of students that should have otherwise been included. As a result, the student's change in status was delayed in reporting to NSLDS. Effect The NSLDS system is not updated with the student information which can cause over-awarding should the student transfer to another institution and the student may not properly enter the repayment period. Questioned Costs N/A Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 1 student, or 2.5% of our sample, had a change in status reported outside of the 60-day reporting time frame. Identification as a Repeat Finding, if applicable N/A Recommendation The College should review their reporting procedures to ensure that student enrollment statuses are reported timely to NSLDS as required by Federal regulations. View of Responsible Officials The College agrees with the finding.

Criteria Section 18004(a)(1) of the Coronavirus Aid, Relief, and Economic Security Act required that institutions submit quarterly reports to the Department of Education that detail the institution's annual expenditures accurately and that the expenditures reconcile with institution's underlying records. Condition During our testing, we noted that the quarterly report for quarter ending December 31, 2022, submitted by the College and posted on the College website, was not accurate and did not reconcile with the College's underlying records. Cause During quarter ending December 31, 2022, the College reported $153,380.06 in quarterly expenditures disbursed to students. However, per underlying records, $1,153,380.06 was actually expended by the College. Inaccurate reporting was caused by human error while preparing the report which was not identified prior to filing and posting the report. Effect The College's quarterly report for quarter ending December 31, 2022, submitted to the Department of Education, was inaccurate. Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the five filed reports selected for testing, one report, or 20% of our sample, had a reporting error. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should implement review procedures to ensure College is in compliance with the program's reporting requirements. View of Responsible Officials The College agrees with the finding. The underlying documentation supporting the quarterly report for the quarter ended December 31, 2022 was correct. However, an error was made in keying the information into the report.

Criteria According to 34 CFR 690.83(b): (1) An institution shall report to the Secretary any change for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student’s Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student’s Payment Data reporting any to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. (2) An institution shall submit, in accordance with the deadline dates established by the Secretary, through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. According to the Federal Register (Volume 86, Number 119): An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records to COD, no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement. In accordance with 34 CFR 668.164(a), title IV, Higher Education Act (“HEA”) program funds are disbursed on the date that the institution: (a) Credits those funds to a student’s account in the institution’s general ledger or any subledger of the general ledger; or (b) pays those funds to a student directly. Title IV, HEA program funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Department of Education. Condition Federal regulations require the College to report to the Federal Government’s Common Origination and Disbursement System (“COD”) Federal Pell Grant disbursements made to students within 15 days of the funds being disbursed to the student. During our testing, we noted four students out of a sample of forty were not reported within the required timeframe by 96-280 days. Cause The College has policies and procedures in place to report the disbursement records to the Department of Education through the COD system within the required fifteen calendar days; however, in this case the procedures were not completed properly. Late reporting was due to significant personnel turnover in the financial aid department of the College causing delay in the correction of rejected COD reporting. Effect The College did not report Pell Grant disbursements to COD within the required time frame.Questioned Costs Not applicable. Perspective Our sample was not, and was not intended to be, statistically valid. Of the forty students selected for testing, four students, or 10% of our sample, was determined to be reported late to the COD. Identification as a Repeat Finding, if applicable Not applicable. Recommendation We recommend that management of the College train additional financial aid department staff on the COD reporting procedures to ensure Pell Grant funds are reported within the required timeframe when management or other staffing has been disrupted. View of Responsible Officials The College agrees with the finding. The Student Financial Services department experienced significant employee turnover in fiscal year 2023. This resulted in a disruption to the process of following up and responding to rejected COD reporting within the required 15-day timeframe.

According to 34 CFR 668.22(f)(2): (i) The total number of calendar days in a payment period or period of enrollment includes all days within the period that the student was scheduled to complete, except that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment and the number of calendar days completed in that period. (ii) The total number of calendar days in a payment period or period of enrollment does not include – (A) Days in which the student was on an approved leave of absence; or (B) For a payment period or period of enrollment in which any courses in the program are offered in modules, any scheduled breaks of at least five consecutive days when the student is not scheduled to attend a module or other course offered during that period of time. According to 34 CFR 668.22(e)(4): Total amount of unearned Title IV assistance to be returned. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student as calculated under paragraph (e)(1) of this section from the amount of Title IV aid that was disbursed to the student as of the date of the institution's determination that the student withdrew. Condition The federal government requires that when a student withdraws from classes, the College calculate the student’s percentage of Title IV aid earned. This is calculated by dividing the number of days the student attended classes by the total number of days in the academic period. The total number of days in the academic period (semester) includes all calendar days between the start and end of academic activities. The Financial Aid Office is responsible for completing the Return of Title IV calculation to determine how much Title IV aid the student earned and how much must be returned to the Department of Education. Once the Return of Title IV calculation is completed, the College is responsible for adjusting the student’s billing statement and returning unearned Title IV funds through the U.S. Department of Education’s Grant Management System (“G6”). During our testing of forty students, we noted: - One instance in which the incorrect number of total days in the semester was used to calculate the student’s percentage of Title IV aid earned. - One instance where the aid returned was different than the amount correctly calculated on the Return to Title IV (“R2T4”) form.Cause The College has policies and procedures to ensure compliance for calculating the Title IV funds to be returned. In the instance of the incorrect number of days used in the calculation, the College incorrectly calculated the enrollment period due to the College utilizing the incorrect semester as basis for calculating Return of Title IV funds. The student enrolled and subsequently withdrew during Spring II semester, which is an accelerated program. However, the College utilized the traditional Spring semester number of days in its calculation. In the instance of the incorrect aid returned, the College did not ensure proper review of the refunding of the Title IV funds when calculating the amount of aid to be returned. Effect The College did not return the appropriate amount of Title IV funds to the Department of Education. Questioned Costs $950.81 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 2 students, or 5% of our sample, had refund amounts that were inaccurately returned to the federal government. Identification as a Repeat Finding, if applicable Not applicable. Recommendation The College should provide training to employees responsible for completing the Return of Title IV calculations and ensure that they have adequate knowledge in the related rules and regulations. The College should implement a formal review process of the Return of Title IV calculations by an individual with proper knowledge of the federal regulations. View of Responsible Officials The College agrees with the finding. The Student Financial Services department experienced significant employee turnover in fiscal year 2023. The remaining staff was challenged to learn and process the Return of Title IV calculations in a short turnaround, while being short-staffed.

Finding number: 2020-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.063, 84.268 Award year: 2020 Criteria According to 34 CFR 685.309(b)(2): Unless [the institution] it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that ? (i) A loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) A student who is enrolled at the school and who received a loan under Title IV of the Act has changed his or her permanent address. The Dear Colleague Letter GEN-12-6 issued by the U.S. Department of Education (?ED?) on March 30, 2012 states that in addition to student loan borrowers, Enrollment Reporting files will include two additional groups of students: Pell Grant and Perkins Loan recipients. According to 2 CFR Part 200, Appendix XI Compliance Supplement updated August 2020: Under the Pell Grant and loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway mailboxes sent by ED via the National Student Loan Data System (?NSLDS?). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition The Federal Government requires the College to report student enrollment changes to the National Student Loan Data System (?NSLDS?) within 60 days. During our testing, we noted one student, out of a sample of forty, was not reported to NSLDS within the required timeframe. Cause The College did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Effect The College did not report the student's status change to NSLDS within the required timeframe, which may impact the student's loan grace period. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the forty students selected for testing, one student, or 2.5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by seven days. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge in the related rules and regulations. This training should include an explanation of the College?s date of determination of withdrawal, the importance of reporting timely and the consequences of late reporting. Additionally, submission of additional rosters may reduce the likelihood of the finding in the future. View of Responsible Officials The College agrees with the finding. The College submitted the appropriate information to the National Student Clearinghouse (?NSC?), the third-party servicer, within the appropriate timeframe. However, NSC failed to submit the file to the National Student Loan Data System (?NSLDS?) within the required timeframe.

Finding number: 2019-001 Federal agency: U.S. Department of Education Program: Student Support Services CFDA #: 84.042 Award year: 2019 Criteria According to 34 C.F.R. 646.32(a): Number of Participants. For each year of the project period, a grantee must serve at least the number of participants that the Secretary identifies in the Federal Register notice inviting applications for a competition. Through this notice, the Secretary also provides the minimum and maximum grant award amounts for the competition. Condition The Federal Government requires that institutions participating in the Student Support Services program serve a minimum number of participants. The College was allocated funds to service 247 participants for the grant year ended August 31, 2018. The College served 217 participants, according to the grant?s Annual Performance Report provided to us. Cause The College did not serve enough eligible participants in its Student Support Services program. Effect As a result, the College is not in compliance with the requirements of the Student Support Services program and may be reprimanded by the Federal Government for failing to meet the minimum requirements of the grant. Questioned Costs Not applicable Perspective Not applicable as the College files one report annually for the Student Support Services program. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should review its selection process and make applicable changes to ensure the required number of eligible students are served by this program. Views of Responsible Officials The College agrees with the finding. Based on previous guidance, the College provided services to students who were identified as ineligible to receive those services for the grant year ended August 31, 2018. The College has implemented a corrective action plan.

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