Massachusetts Bay Community College

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 April 2018: 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 status to the National Student Loan Data System (“NSLDS”) correctly. Of the 40 students selected for testing, 1 student had a status change that was not reported to NSLDS within the required timeframe and 1 student had a status change for which the effective date was not reported to NSLDS properly. Cause The College did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS properly and within the required timeframe. Effect The College did not report the student’s status change to NSLDS properly, 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, 1 student, or 2.5% of our sample, had a status change that was not reported to NSLDS within the required timeframe and 1 student, or 2.5% of our sample, had a status change for which the effective date was not reported to NSLDS properly. 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 accurately and the consequences of late and inaccurate 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.

Finding number: 2023-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Clusters AL #’s: 84.268 Award year: 2023 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 April 2018: 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 1 student, out of a sample of 40, was not reported to NSLDS within the required timeframe by 76 days. 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 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, 1 student, or 2.5% of our sample, had status changes that were not reported to NSLDS within the required timeframe. 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.

Finding number: 2021-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #?s: 84.063, 84.268 Award year: 2021 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 status enrollment changes to the National Student Loan Data System (?NSLDS?) within 60 days. During our testing, we noted two students, out of a sample of 40, were not reported to NSLDS within the required timeframe. Cause The College did not have adequate procedures in place to ensure that status changes were properly reported to NSLDS. Effect The College did not have adequate procedures in place to ensure that students with status changes were reported to NSLDS within the required timeframe. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the forty students selected for testing, two students, or 5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by 176-335 days. 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. Identification as a Repeat Finding, if applicable See finding 2020-001 included in the summary schedule of prior year findings. View of Responsible Officials The College concurs with the auditors? finding.

Finding number: 2021-002 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2021 Criteria According to 34 CFR 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any Title IV, Higher Education Act (?HEA?) program funds, except Federal Work Study (?FWS?) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 1 student, out of a sample of 25, that had unclaimed funds exceeding the federal day limit. Cause The College did not monitor the outstanding check aging to ensure that the 240-day timeframe was met. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There was 1 outstanding check for $799, which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 25 students selected for testing, 1 student, or 4% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Identification as a Repeat Finding, if applicable See finding 2020-002 included in the summary schedule or prior year findings. Recommendation The College should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The College concurs with the auditors? finding.

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 status enrollment changes to the National Student Loan Data System (?NSLDS?) within 60 days. During our testing of forty students with enrollment status changes, we noted the following: 1. Two students' status changes were never reported to NSLDS. 2. Three students had incorrect status changes reported to NSLDS. Cause The College did not have adequate procedures in place to ensure that status changes were properly reported to NSLDS. Effect The College did not report the students? correct status changes to NSLDS, which may impact the students? loan grace periods and enrollment reporting statistics collected by the Department of Education. Questioned Costs Not applicable Perspective Our sample was not, and was not intended to be, statistically valid. Of the forty students selected for testing, five students, or 12.5% of our sample, were not reported correctly. Recommendation The College should provide training to employees responsible for processing information for the NSLDS and ensure that they have adequate knowledge of the related rules and regulations. This training should include an explanation of the status changes, the importance of reporting the correct status changes and the consequences of incorrect reporting. Additionally, the College should implement reconciliation procedures between enrollment records and NSLDS to ensure that information is properly maintained. Identification as a Repeat Finding, if applicable N/A View of Responsible Officials The College concurs with the auditors? finding.

Finding number: 2020-002 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 668.164(l): (1) Notwithstanding any State law (such as a law that allows funds to escheat to the State), an institution must return to the Secretary any Title IV, Higher Education Act (?HEA?) program funds, except Federal Work Study (?FWS?) program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement. (2) If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period. (3) If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check. Condition Federal regulations require an institution to return unclaimed Title IV funds issued by check or EFT within 240 days. During our testing, we noted 7 students, out of a sample of 40, that had unclaimed funds exceeding the federal day limit. Cause The College did not monitor the outstanding check aging to ensure that the 240-day timeframe was met. Effect The College did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were 7 outstanding checks totaled $8,259, which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 students selected for testing, 7 students, or 17.5% of our sample, had unclaimed funds pertaining to federal sources that were not returned to the Department of Education within the 240-day required time frame. Identification as a Repeat Finding, if applicable N/A Recommendation The College should examine its policies and procedures related to unclaimed funds including the process and time frame for identifying aged balances and the process for cancelling checks and returning funds to the Department of Education. View of Responsible Officials The College concurs with the auditors? finding.

Finding number: 2019-001 Federal agency: U.S. Department of Education Programs: Federal Work Study (?FWS?) CFDA #: 84.033 Award year: 2019 Criteria According to 34 C.F.R. Section 675.18(g): For the 2000-2001 award year and subsequent award years, an institution must use at least seven percent of the sum of its initial and supplemental FWS allocations for an award year to compensate students employed in community service activities. In meeting this community service requirement, an institution must include at least one: (1) Reading tutoring project that employs one or more FWS students as reading tutors for children who are preschool age or are in elementary school; or (2) Family literacy project that employs one or more FWS students in family literacy activities. According to 34 C.F.R Section 675.2(b): The Secretary defines other terms used in this part as follows: Community services: Services which are identified by an institution of higher education, through formal or informal consultation with local nonprofit, governmental, and community-based organizations, as designed to improve the quality of life for community residents, particularly low-income individuals, or to solve particular problems related to their needs. Condition Regulations require that the College use at least 7% of its Federal Work Study funds to compensate students employed in a community service activity. In addition, at least one student must be compensated for holding a literacy related community service position. As of June 30, 2019, the College did not have a Federal Work Study program that meet the definition of community service, and as such, did not have a student who was employed in a work study program related to literacy. Cause The College has had difficulty participating in work study programs related to community service due to two major factors: 1. The College is a small community college, where much of its population prefers to remain on campus, and 2. The College is in Wellesley, MA, an affluent area, with fewer than normal community service opportunities. As such there are fewer opportunities for the College to engage in community service related activities on a regular basis within a reasonable distance from campus. Effect The College does not have Federal Work Study programs that involve community service and as such did not meet the Federal Work Study earmarking requirement as well as the Federal Work Study literacy requirement. Questioned Costs $3,227 Perspective According to Curtis Cormier, Director of Financial Aid, there were no work study programs that could be considered community service within a reasonable radius of the College. Recommendation We recommend that the College continue in their attempts to pursue work study programs at local organizations and K-12 schools in the area. Identification as a Repeat Finding, if applicable See finding 2018-003 included in the summary schedule of prior year findings. Views of Responsible Officials The College concurs with the auditors? finding.