Westfield State UniversityHigher Education

Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2025 Criteria According to 2 CFR Part 200, Appendix XI Compliance Supplement updated May 2024: 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 or accessed on the Enrollment Maintenance Page 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 Westfield State University to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 3 out of 40 students was reported late to the NSLDS by 220 days. Cause Westfield State University did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely. Effect Westfield State University did not report the student’s correct status within the required timeframe, which may impact the students’ 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, 3 students, or 7.5% of our sample was not reported within the required timeframe. Identification as a Repeat Finding, if applicable See finding 2024-001 included in Management’s Summary Schedule of Prior Audit Findings.Recommendation The University should strengthen its controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials Westfield State University agrees with the finding.

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063, 84.268 Award year: 2024 Criteria According to 2 CFR Part 200, Appendix XI Compliance Supplement updated May 2024: 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 or accessed on the Enrollment Maintenance Page 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 Westfield State University to report student enrollment changes to the National Student Loan Data System (“NSLDS”) within 60 days. During our testing, 1 out of 40 students was reported late to the NSLDS by 1 day. Cause Westfield State University did not have the proper review procedures in place to ensure enrollment status changes were being reported to NSLDS timely. Effect Westfield State University did not report the student’s correct status within the required timeframe, which may impact the students’ 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 was not reported within the required timeframe. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should strengthen its controls surrounding the review of the NSLDS reporting process to ensure they are in compliance with federal regulations. View of Responsible Officials Westfield State University agrees with the finding.

Finding number: 2020-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster CFDA #: 84.063 and 84.268 Award year: 2020 Criteria According to 34 CFR 685.309(b)(2): Unless Westfield State University 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 June 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 University to report student enrollment changes to the National Student Loan Data System (?NSLDS?) within 60 days. During our testing, we noted three students, out of a sample of 40, that had incorrect effective dates reported to NSLDS. Also, during our testing, we noted one student, out of a sample of 40, that was reported to NSLDS two days beyond the required timeframe. Cause The University did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS. Effect The University did not report the students? correct effective dates to NSLDS, which may impact the students? loan grace periods. The University did not report the students? status changes to NSLDS within the required timeframe, which may impact the students? 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, three students, or 7.5% of our sample, had incorrect effective dates reported to NSLDS and one student or 2.5% of our sample, had status changes that were not reported to NSLDS within the required timeframe by 2 days Identification as a Repeat Finding, if applicable See finding 2019-001 included in the summary schedule of prior year findings. Recommendation The University 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 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 University. View of Responsible Officials The University agrees with the finding.

Finding number: 2020-002 Federal agency: U.S. Department of Education Programs: Higher Education Emergency Relief Fund CFDA #: 84.425E Award year: 2020 Criteria According to 2 CFR 200.403: Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also ? 200.306(b). (g) Be adequately documented. See also ?? 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3). Condition The Student Financial Aid Office is responsible for awarding student emergency grants in accordance with the University?s documented distribution plan. During our testing, we noted one student expenditure out of a sample of 39 total student and institutional expenditures, who received a student emergency grant of $500 instead of the $400, as prescribed by the University?s documented student distribution plan. Effect The Student Financial Aid Office awarded a student an additional $100 of emergency grant funding that was not in accordance with the University?s documented student distribution plan. Questioned Costs $100 Perspective Our sample was not, and was not intended to be, statistically valid. Of the 40 expenditures selected for testing, one student expenditure, or 2.5% of our sample, was greater than the amount the student would have otherwise been eligible for. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University should create procedures to ensure the University is in compliance with their policy in how they distribute student emergency grants. View of Responsible Officials The University agrees with the finding.

Criteria According to 34 CFR 685.309(b)(2): Unless Westfield State University 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 June 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 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, that had an incorrect effective date reported to NSLDS, a second student, out of a sample of forty, not reported to NSLDS within 60 days, and noted a third student, out of the same sample of forty, whose status change was not reported to NSLDS. Cause The University did not have adequate procedures in place to ensure that students with status changes had their effective date correctly reported to NSLDS, the University did not have adequate procedures in place to ensure students were reported timely to NSLDS, and the University did not have adequate procedures in place to ensure that status changes were properly reported to NSLDS within the required timeframe. Effect The University did not report the correct effective date for one student's status change and did not report the status change of another student at all 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, three students, or 7.5% of our sample, had issues with status change reporting to NSLDS, including one student with an incorrect effective date reported for the status change and another student whose status change was not reported to NSLDS. Identification as a Repeat Finding, if applicable Not applicable Recommendation The University 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 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 University. View of Responsible Officials The University agrees with the finding.

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 2 student(s), out of a sample of 10, that had unclaimed funds exceeding the federal day limit by 64-115 days. Cause The University has policies and procedures in place to monitor the outstanding check aging to ensure that the 240-day timeframe is met, however, in these cases the procedures were not completed properly. Effect The University did not return Title IV unclaimed funds to the Department of Education within the required 240-day time frame. Questioned Costs There were two outstanding check(s) totaled $3.70, which pertained specifically to federal-sourced funds. Perspective Our sample was not, and was not intended to be, statistically valid. Of the 10 students selected for testing, 2 students, or 20% 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 Not applicable Recommendation The University 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 University agrees with the finding.

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