Middlesex Community College

Criteria According to 34 CFR Section 690.62(a): Calculation of a Federal Pell Grant: The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year. According to 34 CFR Section 690.2(c): Annual award: The Federal Pell Grant award amount a full-time student would receive under the payment schedule for a full academic year in an award year, and the amount a three-quarter time, half-time, and less-than-half-time student would receive under the appropriate disbursement schedule for being enrolled in that enrollment status for a full academic year in an award year. Disbursement Schedule: A table showing the annual awards that three-quarter, half-time, and less-than-half-time students at term-based institutions using credit hours would receive for an academic year. This table is published annually by the Secretary and is based on: (1) A student's expected family contribution, as determined in accordance with Title IV, Part F of the HEA; and (2) A student's attendance costs as defined in Title IV, Part F of the HEA. (3) The amount of funds available for making Federal Pell Grants. Condition Federal regulations require institutions to award Federal Pell Grants in accordance with the appropriate disbursement schedule for three-quarter, half-time, and less-than-half-time students based on the students’ EFC and cost of attendance. During our testing of forty students, one student was not awarded the proper amount of Pell Grant funds. Cause The College had to calculate the student’s financial aid manually based on the type of certification program the student was enrolled in. The student’s Federal Pell Grant was correctly calculated based on the student’s enrollment status, expected family contribution, and attendance costs; however, the total amount of funds disbursed was more than what was originally calculated. Inaccurate disbursing of the award was caused by human error while inputting the calculated Pell award which was not identified prior to disbursing the funds to the student. Effect By inputting the incorrect award, the student was over awarded Federal Pell Grant Costs Questioned Costs Federal Pell Grant overpayment of $128. 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, received an incorrect Federal Pell Grant award. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the College review, and if necessary, update, the policies and procedures for awarding aid and ensuring enrollment statuses are correct to ensure Federal Pell Grant award amounts are properly calculated. Additionally, financial aid awards should be reviewed by management prior to disbursing funds to students. View of Responsible Officials The College agrees with the finding.

Corrective Action Plan: The finding was due to administrative error when a staff member failed to manually input the correct student’s Pell award after the calculation was reviewed. The College has corrected the error and returned the $128 Pell funds back to the U.S. Department of Education. The College has reviewed all manually calculated and inputted Pell funds disbursed in the 2024 fiscal year noting no other discrepancies. Timeline for Implementation of Corrective Action Plan: Present Contact Person Kimberly Tibbetts, Director of Financial Aid

Criteria According to 34 CFR Section 685.304(b)(1): A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school. According to 34 CFR Section 685.304(b)(7): The school must maintain documentation substantiating the school's compliance with this section for each student borrower. Condition Federal regulations require institutions to perform exit counseling for all graduates and withdrawn students who borrow Federal Direct Student Loans. During our testing of forty students, one student who was awarded a Federal Direct Student Loan and graduated in the fiscal year did not receive exit counseling. Cause During review of Federal Direct Student Loan borrowers who graduated, the College recognized that only students who had a manual Direct Student Loan exit requirement (“DLEXIT”) added into their record were sent the required exit counseling notification letter. The DLEXIT requirement added to the applicable student recorded is needed to trigger creation and mailing of the Director Loan exiting counseling letter. The College became aware that job code (“RRREXIT”) out of their Enterprise Resource Planning system (“Banner”) had not been manually run. RRREXIT is a Banner job that identifies Direct Student Loan borrowers who have graduated, dropped below half-time, or withdrew completely and adds the DLEXIT requirement onto the student’s records. The staff member responsible for running the entire Direct Student Loan counseling letter process did not carry that part of the process. Effect The College did not provide exit counseling to a graduate student who was awarded Federal Direct Student Loans. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of forty students selected for testing, one student, or 2.5% of our sample, did not receive exit counseling. Identification as a Repeat Finding, if applicable Not applicable Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures for Federal Direct Student Loan exit counseling notifications. Additionally, the staff members involved in process should have proper training and be made aware of all the compliance requirements for which they are responsible. View of Responsible Officials The College agrees with the finding.

Corrective Action Plan: The College has started to run the RRREXIT job along with creation and mailing process of Federal Director Student Loan exit counseling letters biweekly. The College is working with a consulting firm to automate the process so that scheduling software will be used to kick off and complete the process entirely. The College will receive an email notification that it was completed successfully. A different staff member will be designated to oversee the process to ensure that the letters are generated and mailed biweekly. The College is developing a Question & Answer process to review different areas of the financial aid process to make sure the College is in compliance. Timeline for Implementation of Corrective Action Plan: Present Contact Person Kimberly Tibbetts, Director of Financial Aid

Criteria 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 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 institution 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 (?G5?). The institution has 45 days from the date they determined the student withdrew to return any unearned portions of Title IV funds. During our testing, we noted a student, out of a sample of 25, where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form. Cause The College failed to have the proper review procedures in place to ensure that the refund calculated on the R2T4 form matched the return of funds that was applied to the student's billing statement. Effect The College did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs $20 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 25 students selected for testing, a single student, or 4% of our sample, had an incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should review its current policies and procedures to ensure the amount of federal aid returned agrees with the amount calculated on the R2T4 form. Views of Responsible Officials The College agrees with this finding. Management acknowledges that the refunded amount was incorrect.

Corrective Action Plan: In 2019-2020, the College began using its student information system, Banner, to process Return to Title IV calculations. In the past, the College used FAA/CPS software, but that did not allow users to query off the data in Banner. Using Banner form SFAWDRL as well as Banner reports RPRTIVI, and RPATIVC, users can query and review data. The Director of Financial Aid will run the above reports on a bi-weekly basis and spot-check that the amount of disbursed aid in the Financial Aid award screen, RPAAWARD, matches that of the Student Account form, TSAAREV. If anomalies exist, they will be corrected accordingly. Timeline for Implementation of Corrective Action Plan: Present Contact Person Barbara Winchell, Director of Financial Aid

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 2019: 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 institutions to report student enrollment changes to the National Student Loan Data System (?NSLDS?) within 60 days. During our testing, we noted a student, out of a sample of 40, who was not reported to NSLDS within the required timeframe. Cause The College did not have adequate procedures in place to ensure that the student with a status change was reported to NSLDS within the required timeframe. Effect The College did not report the student?s status changes to NSLDS within the required timeframe, which may impact the student's loan grace periods. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, a single student, or 2.5% of our sample, had a status change that was not reported to NSLDS within the required timeframe of 60 days. Identification as a Repeat Finding, if applicable See finding 2018-003 in Management?s Summary Schedule of Prior Audit Findings. Recommendation We recommend that the College ensure that the employees involved in reporting student status changes to NSLDS have proper training and are aware of all of the compliance requirements for which they are responsible. This training should include an explanation of the effective date of a student?s withdrawal, the importance of reporting the correct effective date, and the consequences of incorrect reporting. This oversight should also ensure that the effective date reported to NSLDS is consistent with the date the student separated from the College. Views of Responsible Officials The College agrees with this finding.

Corrective Action Plan: An investigation of the student's record indicated that this student was incorrectly reported in Fall 2018. The College began working with an outside consultant, College Aid Services, shortly after that reporting term. College Aid Services was hired in an effort to identify populations potentially out of compliance. A query of the data indicated that a cohort of students needed to be updated in May 2019, and this student was part of that group. A plan was devised to update all pertinent time-status dates for multiple semesters in the College's system of record, Banner, and The National Student Clearinghouse ("NCH"). As this student was first identified after the semester closed, the College relied heavily on NCH advice on protocol for updating a closed term. During this time, development of one-off Clearinghouse updates was under development and this student was missed. For the future, the College has made arrangements to update the students? records with College Aid Services. Additionally, management has adjusted protocol to 1: better identify students with time-status date issues and 2: ensure unified collaboration and follow-up on manual updates to both Banner and NCH. Timeline for Implementation of Corrective Action Plan: Present Contact Person Barbara Winchell, Director of Financial Aid

2018-003

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2017-001

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2017-002

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2017-003

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2016-002

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2016-003

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2016-005

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2015-003