Greenfield 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 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, that had an incorrect effective date reported to NSLDS and 1 student, out of a sample of 40, 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 had their effective date correctly reported to NSLDS and within the required timeframe. Effect The College did not report the student’s correct effective dates to NSLDS and 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, had an incorrect effective date reported to NSLDS and 1 student, or 2.5% of our sample, was not reported to NSLDS within the required timeframe. Identification as a Repeat Finding, if applicable Yes, see finding 2024-001. 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 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. View of Responsible Officials The student unofficially withdrew from the Fall 2024 term. The student did not notify the College that they had stopped attending, and the Institution is not required to take attendance. The student appeared on the “O/F” grade report after failing all courses. When faculty enter a failing grade, they are asked to provide the student’s last date of attendance (“LDA”) when available. One instructor reported an LDA of October 2, 2024. This information was not received by the College until December 20, 2024. December 20, 2024, was therefore the date the Institution determined the student had unofficially withdrawn. However, the effective withdrawal date for Return of Title IV (“R2T4”) purposes was October 2, 2024, based on the documented last date of attendance. The withdrawal date reported to NSLDS should reflect the effective withdrawal date rather than the date the Institution became aware of the withdrawal. The College agrees with the finding.

Corrective Action Plan: On January 29, 2025, the Registrar updated the student’s withdrawal date in the Banner system (SFAWDRL). We expected the revision to be included in the subsequent monthly enrollment reporting file submitted to the National Student Clearinghouse (NSC). During our review, we determined that this student was not included in the February 2025 NSC submission. To prevent this issue in the future, the Registrar’s Office will manually report revised withdrawal dates directly to NSC for any student identified by the Financial Aid Office as an unofficial withdrawal requiring a date adjustment. In addition, the college may collaborate with the IT department to review the parameters used to generate the monthly NSC enrollment reporting extract to ensure that students with revised withdrawal dates are consistently included in future submissions. Contact Person Mark Boudreau, Comptroller

2024-001

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster ALN #: 84.063 and 84.268 Award year: 2024 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 5 students, out of a sample of 40, that had incorrect effective dates reported to NSLDS, 4 students, out of a sample of 40, that had an incorrect student status and 4 students, out of 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 students with status changes had their effective date correctly reported to NSLDS and within the required timeframe. Effect The College did not report the students’ correct effective dates to NSLDS and 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, 5 students, or 12.5% of our sample, had incorrect effective dates reported to NSLDS, 4 students, or 10% of our sample, had an incorrect student status and 4 students, or 10% of our sample, were not reported to NSLDS within the required timeframe. Identification as a Repeat Finding, if applicable Yes, see finding 2023-001. 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 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. View of Responsible Officials The College agrees with the finding.

Finding number: 2024-001 Corrective Action Plan: To ensure that the college is using the same effective date for (unofficial) withdrawal on both the R2T4 calculations and for reporting unofficial withdrawal enrollment changes to NSLDS, the financial aid office will forward the list of students who are determined to have unofficially withdrawn and their associated date of unofficial withdrawal to the registrar's office at the end of each term. The registrar's office will then adjust all students' records in their SIS (Banner) as needed prior to submitting their report to NSC/NSLDS. This corrective action plan was finalized in June 2024. Finding 2024-01 occurred prior to the action plan’s implementation. Timeline for Implementation of Corrective Action Plan: June 2024 Contact Person Mark Boudreau, Comptroller

2023-001

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 5 students, out of a sample of 40, that had incorrect effective dates reported to NSLDS and 2 students, out of 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 students with status changes had their effective date correctly reported to NSLDS and within the required timeframe. Effect The College did not report the students’ correct effective dates to NSLDS and 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, 5 students, or 12.5% of our sample, had incorrect effective dates reported to NSLDS and 2 students, or 5% of our sample, 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 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. View of Responsible Officials The College agrees with the finding.

Finding number: 2023-001 Corrective Action Plan: An internal review of our process for reporting Pell payments to Common Origination & Disbursement (COD) reveal that the vast majority of Pell payments are reported within 2 business of disbursement. The Pell payment in question was disbursed two weeks after our scheduled fall disbursement date and reported to COD 11 days late. The disbursement occurred once the student completed all outstanding financial aid requirements. The procedures for reporting all Title IV payments and disbursements to COD has been reviewed with the staff members responsible for transmitting origination and disbursement records to COD. Procedures have been developed to more readily identify financial aid disbursements that take place outside of the established disbursement date for the term. Timeline for Implementation of Corrective Action Plan: Immediately Contact Person Mark Boudreau, Comptroller

Finding number: 2019-001 Federal agency: U.S. Department of Education Programs: Federal Pell Program CFDA #?s: 84.063 Award year: 2019 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 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 (?G5?). The College 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 one student, out of a sample of ten, where the aid returned was different than the amount correctly calculated on the Return to Title IV (?R2T4?) form. Cause The College used the date of the withdrawal form completion to perform the R2T4 calculation instead of the student?s last date of attendance. Effect The College did not return the correct amount of Title IV funds to the Department of Education. Questioned Costs The total amount of Title IV Aid the student should have earned is $225.55. Instead the student earned $394.72, thus, resulting in a questioned cost of $168.17. Perspective Our sample was not, and was not intended to be, statistically valid. Of the ten students selected for testing, one student, or 10% of our sample, had the incorrect amount of Title IV funds returned. Identification as a Repeat Finding, if applicable Not applicable Recommendation The College should review their 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 the finding.

Finding number: 2019-001 Federal agency: U.S. Department of Education Programs: Federal Pell Program CFDA #?s: 84.063 Award year: 2019 Corrective Action Plan: The College reviewed its process and form for calculating the return of federal Title IV funds. The date the school makes the determination of the student?s withdrawal and the date of withdrawal are both present on our R2T4 form; since the finding we have edited our form to highlight the difference between the two dates in order to make the withdrawal date for calculation more distinguishable from the school?s determination date. This step will ensure that our form and data entry processes are in compliance with the definition for R2T4 calculations as stated in the Federal Register section 34 CFR 668.22(e)(4). This finding resulted in the school having to return $169.17 which was done immediately upon the finding on June 17, 2019. Since the finding, we also reviewed our R2T4 calculations for the same period as part of an internal review and found no other errors. Timeline for Implementation of Corrective Action Plan: The new form was fully implemented on July 1, 2019 along with a staff development training for R2T4 procedures. Contact Person Linda Desjardins Director of Financial Aid

Finding number: 2019-002 Federal agency: U.S. Department of Education Programs: Federal Pell Program CFDA #?s: 84.063 Award year: 2019 Criteria According to 34 CFR 668.56: (a) For each award year the Secretary publishes in the Federal Register notice the FAFSA information that an institution and an applicant may be required to verify. (b) For each applicant whose FAFSA information is selected for verification by the Secretary, the Secretary specifies the specific information under paragraph (a) of this section that the applicant must verify. According to the Federal Register, Volume 82, No. 86: The following chart lists, for the 2018?2019 award year, the FAFSA information that an institution and an applicant and, if appropriate, the applicant?s parent(s) or spouse may be required to verify under 34 CFR 668.56: [The FAFSA information below is included in the chart in the Federal Register] Income information for tax filers a. Adjusted Gross Income (AGI) b. U.S. Income Tax Paid c. Untaxed Portions of IRA Distributions d. Untaxed Portions of Pensions e. IRA Deductions and Payments f. Tax Exempt Interest Income g. Education Credits Condition The Federal Government requires the College to verify students? FAFSA information for students who the Federal Government selects in their verification process. The Federal Government issues a FAFSA Verification - IRS Tax Return Transcript matrix to assist financial aid administrators in verifying income information for tax filers. Out of a sample of 11 students selected for verification, one student had their FAFSA information verified incorrectly. Cause The College has policies and procedures in place to properly verify the FAFSA information. However, in this case the procedures were not completed properly. Effect The FAFSA information was incorrect on the student's Institutional Student Information Record (ISIR) which resulted in an inaccurate calculation of the Expected Family Contribution (EFC). The College uses the EFC to determine the student's federal student aid eligibility and financial award and an incorrect EFC can result in an improper award. Questioned Costs Non-determinable Perspective Our sample was not, and was not intended to be, statistically valid. Of the forty students selected for testing, eleven students were flagged for verification, of which, one student's ISIR or 9% were not updated for the results of the verification changes. Identification as a Repeat Finding, if applicable See finding 2018-001 included in the summary schedule of prior year findings. Recommendation The College should continue to strengthen their controls surrounding verification. The College should implement policies that require all student ISIR?s subject to verification be reviewed once the verification process is complete. The reviewer should be well-versed in the verification process and requirements. Views of Responsible Officials The College agrees with the finding.

Finding number: 2019-002 Federal agency: U.S. Department of Education Programs: Federal Pell Program CFDA #?s: 84.063 Award year: 2019 Corrective Action Plan: During the verification of the student?s FAFSA information, the school routinely reviews and verifies the ISIR data elements as defined in the federal register section 34 CFR 668.56; specifically for the items listed in the chart of the federal register: AGI; U.S. Income; Untaxed IRA Distributions; Untaxed Portions of Pensions; IRA Deductions and Payments; Tax Exempt Interest Income; and, Education Tax Credits. In the instance of this finding, the Education Tax Credits were incorrectly verified. The error resulted in lowering the student?s EFC from $1315 down to $1141; meaning the student became eligible for more Pell grant. No return of funds was warranted in this instance; in fact, the student was entitled to a greater amount of Title IV Pell grant. Since this finding, the school has reviewed its verification procedures and has implemented a step to review the verification once it?s completed. We also made improvements to our data elements matrix and flow sheet for counselor use during the review process. In this instance, it was also noted that the student did not use the IRS Data Retrieval Tool. GCC is located in a very rural region of Massachusetts, not all communities have broadband access. Nevertheless, we will continue to encourage the use of the IRS Data Retrieval tool by all our FAFSA Applicants. Timeline for Implementation of Corrective Action Plan: The improved review and improvements to the flow sheet were fully implemented on July 1, 2019. Contact Person Linda Desjardins Director of Financial Aid

2018-001

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2017-002

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2016-002

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2015-001