FAC Explorer

Audit 345265

FY End
2024-06-30
Total Expended
$3.53M
Findings
6
Programs
10
Organization: Greenfield Community College (MA)
Year: 2024 Accepted: 2025-03-08
Auditor: Withumsmith+brown PC

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
526332 2024-001 Significant Deficiency Yes N
526333 2024-001 Significant Deficiency Yes N
526334 2024-002 Significant Deficiency Yes L
1102774 2024-001 Significant Deficiency Yes N
1102775 2024-001 Significant Deficiency Yes N
1102776 2024-002 Significant Deficiency Yes L

Programs

ALN Program Spent Major Findings
84.063 Federal Pell Grant Program $2.40M Yes 2
84.268 Federal Direct Student Loans $515,560 Yes 1
21.027 Coronavirus State and Local Fiscal Recovery Funds $149,202 - 0
84.033 Federal Work-Study Program $148,196 Yes 0
84.048 Career and Technical Education -- Basic Grants to States $127,181 - 0
17.261 Workforce Data Quality Initiative (wdqi) $69,216 - 0
84.007 Federal Supplemental Educational Opportunity Grants $56,043 Yes 0
84.425 Education Stabilization Fund $45,363 - 0
93.493 Congressional Directives $13,741 - 0
84.116 Fund for the Improvement of Postsecondary Education $7,597 - 0

Contacts

Name Title Type
NJNPSELLAHY3 Christopher D Evans Auditee
4018650849 David Diiluis Auditor
No contacts on file

Notes to SEFA

Title: Note 1 - Basis of Presentation Accounting Policies: Accrual Basis De Minimis Rate Used: N Rate Explanation: The College has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) includes the federal award activity of Greenfield Community College (the “College”) under programs of the Federal Government for the year ended June 30, 2023. The information on this Schedule is prepared in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). Because the Schedule presents only a selected portion of the operations of the College, it is not intended to, and does not present, the financial position, changes in net position or cash flows of the College.
Title: Note 2 - Summary of Significant Accounting Policies Accounting Policies: Accrual Basis De Minimis Rate Used: N Rate Explanation: The College has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance.
Title: Note 3 - Indirect Cost Rate Accounting Policies: Accrual Basis De Minimis Rate Used: N Rate Explanation: The College has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The College has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance.
Title: Note 4 - Federal Student Loan Programs Accounting Policies: Accrual Basis De Minimis Rate Used: N Rate Explanation: The College has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. Direct Student Loan Program The College disbursed $515,560 of loans under the Federal Direct Student Loans program, which include Stafford Subsidized and Unsubsidized Loans and Parent Plus Loans. It is not practical to determine the balances of the loans outstanding to students of the College under the program as of June 30, 2024. The College is only responsible for the performance of certain administrative duties and, accordingly, these loans are not included in the College’s financial statements.

Finding Details

Finding 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 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 2024-002
Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Federal Pell Grants ALN #: 84.063 Award year: 2024 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 83, Number 233): 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 students within 15 days of the funds being disbursed to the student. During our testing, we noted 2 students, out of a sample of 40, that was not reported within the required timeframe by 12-13 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. 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 40 students selected for testing, 2 students, or 5% of our sample, was determined to be reported late to the COD by 12-13 days. Identification as a Repeat Finding, if applicable Yes, see finding 2023-002 Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell Grant funds are reported within the required timeframe. View of Responsible Officials The College agrees with the finding. (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. 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
Finding 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 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 2024-002
Finding number: 2024-002 Federal agency: U.S. Department of Education Programs: Federal Pell Grants ALN #: 84.063 Award year: 2024 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 83, Number 233): 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 students within 15 days of the funds being disbursed to the student. During our testing, we noted 2 students, out of a sample of 40, that was not reported within the required timeframe by 12-13 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. 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 40 students selected for testing, 2 students, or 5% of our sample, was determined to be reported late to the COD by 12-13 days. Identification as a Repeat Finding, if applicable Yes, see finding 2023-002 Recommendation We recommend that management of the College review, and if necessary, update the policies and procedures to ensure all Pell Grant funds are reported within the required timeframe. View of Responsible Officials The College agrees with the finding. (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. 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