EIN: 660177776
UEI: PMELJCUDNL17
Data as of August 21, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 30, 2026 (39 days from today).
What is a management decision? →Criteria For disaster grants funded by the U.S. Department of Homeland Security – Federal Emergency Management Agency (FEMA), nonfederal entities must record expenditures on the schedule of expenditures of federal awards (SEFA) when 1) FEMA has approved the nonfederal entity’s Project Worksheet (PW) and 2) when the nonfederal entity has incurred eligible expenditures. Federal awards expended in years subsequent to the fiscal year in which the PW is approved are to be recorded on the nonfederal entity’s SEFA in those subsequent years. Condition and Context As a result of our audit procedures, the engagement team identified $2,372,969 of expenditures not properly reported in the SEFA for the fiscal year ended June 30, 2025. Amounts in the SEFA were corrected by management. Cause and Possible Asserted Effect The cause of these errors was a lack of sufficient controls in place to ensure that the SEFA is completeand accurate
Show full finding ▾Hide full finding ▴Criteria For disaster grants funded by the U.S. Department of Homeland Security – Federal Emergency Management Agency (FEMA), nonfederal entities must record expenditures on the schedule of expenditures of federal awards (SEFA) when 1) FEMA has approved the nonfederal entity’s Project Worksheet (PW) and 2) when the nonfederal entity has incurred eligible expenditures. Federal awards expended in years subsequent to the fiscal year in which the PW is approved are to be recorded on the nonfederal entity’s SEFA in those subsequent years. Condition and Context As a result of our audit procedures, the engagement team identified $2,372,969 of expenditures not properly reported in the SEFA for the fiscal year ended June 30, 2025. Amounts in the SEFA were corrected by management. Cause and Possible Asserted Effect The cause of these errors was a lack of sufficient controls in place to ensure that the SEFA is completeand accurate
As a corrective action, the University will implement the following: Assignment of a dedicated resource: A person will be appointed as responsible for the FEMA project to oversee the functioning of the control, ensuring the proper collection and monitoring of the information (“FEMA Coordinator”). We are already coordinating with the Office of the President for the corresponding approval of the new structure. Inclusion of obligated and incurred expenditures related to the Department of Homeland Security/FEMA in the corresponding SEFA report for each year: We have instructed the Institutional Director of the Office of Accounting for External Programs to notify the FEMA Coordinator, the Associate VP of Management and Budget, the Associate VP of Accounting and Finance and the VP of Management, Finance and Systemic Services when the automated SEFA report is ready, so that the FEMA Coordinator can provide her all the information to be included for the Department of Homeland Security/FEMA. The Institutional Director will include this information and send the amended SEFA to the four persons mentioned above. Implementation timeline: We estimate that these actions will be fully operational by July 1, 2026. We are committed to closely monitoring these measures and ensuring their successful implementation, guaranteeing compliance with internal control standards.
FAC accepted this audit on March 20, 2024 — management decision was due September 20, 2024.
Finding No. 2023–001 - Special Tests and Provisions - Return of Title IV Funds - San Germán Campus Federal Program Name Student Financial Assistance Programs Cluster - Federal Direct Student Loan Program (DL) Assistance Listing 84.268 Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria According to 34 CFR 668.22(j)(2) for an institution that is not required to take attendance, it must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the: (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e)(5) of this section; (ii) Academic year in which the student withdrew; or (iii) Educational program from which the student withdrew. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all thirteen (13) students from the selected campuses that failed to earn a passing grade, for a total of seventy three (73) students, and noted that for one (1) student, the determination of withdrawal was performed after the required 30 days, as follows: Table Cause At the end of the term in the San Germán campus, the professor certified a non-passing grade and later changed it to an unauthorized withdrawal, resulting in an administrative withdrawal for the student. However, such administrative withdrawal was not determined within the required period. As a result, the return of Title IV funds was not processed on a timely manner. Effect As a result of this instance of noncompliance, the USDE may issue warnings and/or impose penalties on the University. Also, the incorrect return of Title IV funds could limit the students’ future eligibility to Title IV funds. Questioned Costs None. Context Of the 2,417 withdrawals from the selected campuses for the year ended June 30, 2023, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all thirteen (13) students from the selected campuses that failed to earn a passing grade, for a total of seventy-three (73) students, and noted one (1) instance of noncompliance. Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Pell funds: Table Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Direct Loans: Table Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2022-001). Recommendation The University San Germán Campus’ management should reinforce its procedures to ensure the identification and timely resolution of instances in which students withdrew without providing notification to the University. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 66-67.
Show full finding ▾Hide full finding ▴Finding No. 2023–001 - Special Tests and Provisions - Return of Title IV Funds - San Germán Campus Federal Program Name Student Financial Assistance Programs Cluster - Federal Direct Student Loan Program (DL) Assistance Listing 84.268 Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria According to 34 CFR 668.22(j)(2) for an institution that is not required to take attendance, it must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the: (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e)(5) of this section; (ii) Academic year in which the student withdrew; or (iii) Educational program from which the student withdrew. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all thirteen (13) students from the selected campuses that failed to earn a passing grade, for a total of seventy three (73) students, and noted that for one (1) student, the determination of withdrawal was performed after the required 30 days, as follows: Table Cause At the end of the term in the San Germán campus, the professor certified a non-passing grade and later changed it to an unauthorized withdrawal, resulting in an administrative withdrawal for the student. However, such administrative withdrawal was not determined within the required period. As a result, the return of Title IV funds was not processed on a timely manner. Effect As a result of this instance of noncompliance, the USDE may issue warnings and/or impose penalties on the University. Also, the incorrect return of Title IV funds could limit the students’ future eligibility to Title IV funds. Questioned Costs None. Context Of the 2,417 withdrawals from the selected campuses for the year ended June 30, 2023, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all thirteen (13) students from the selected campuses that failed to earn a passing grade, for a total of seventy-three (73) students, and noted one (1) instance of noncompliance. Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Pell funds: Table Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Direct Loans: Table Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2022-001). Recommendation The University San Germán Campus’ management should reinforce its procedures to ensure the identification and timely resolution of instances in which students withdrew without providing notification to the University. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 66-67.
Corrective Action Plan The Inter American University of Puerto Rico (IAUPR) will implement the following actions to strengthen compliance with the 30-day reglementary period for the R2T4 determination: 1. IAUPR will also prepare compulsory online or face-to-face training sessions which all full and part-time faculty will be required to take in August and January of each year. The training sessions will review grading policies and any other procedures required for compliance with Federal Regulations. The primary executives of each academic unit, through the Deans of Academic Affairs, will be responsible for ensuring and certifying to the Vice President of Academic and Student Affairs that all faculty participated in the training. 2. The Deans of Academic Affairs or their designees at each academic unit will monitor the entry of final grades in the Banner System and report any suspicious grades and suspected cases of noncompliance with Federal Regulations to the chairs of the academic departments for immediate follow-up and correction. 3. IAUPR will develop a course of action whereby a department chair or dean of academic affairs may correct or update a grade in the Banner System, based on the academic information available, when a faculty member is unable to do so because of a force majeure. 4. In recurrent cases of noncompliance, the primary executives of each academic unit will send a written communication to faculty that do not comply with established procedures and include a copy of the communication in the professors' academic/administrative files.
2022-001
Finding No. 2023–002 - Special Tests and Provisions – Disbursements to or on behalf of students Federal Program Name Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing 84.007 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 668.164(h) states that Title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. Condition As part of our testing of 27 students who received FSEOG funds, we noted one (1) instance for which the University did not pay the credit balance to the student within the 14 days required. Cause The provisions of Title IV allow the University to collect debts between terms through transfers during the academic year up to an amount of $200.00. In this case, the Fajardo Campus personnel attempted to collect a prior term debt from a student with an available credit balance; however, an incorrect code was inadvertently used in this transaction. Therefore, the remaining credit balance did not get paid within the 14 days as required by Title IV. Effect As a result of this instance of noncompliance, the USDE may issue warnings and/or impose penalties on the University. Questioned Costs None. Context Of the 6,423 students who received FSEOG funds from the selected campuses for 2023, we selected 27 students for testing and noted one (1) instance in which the University did not comply with the disbursements to or on behalf of students’ requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The University should enhance its control procedures to ensure all credit balances in a student’s account are paid directly to the student within the required timeframe. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 68-69.
Show full finding ▾Hide full finding ▴Finding No. 2023–002 - Special Tests and Provisions – Disbursements to or on behalf of students Federal Program Name Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing 84.007 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 668.164(h) states that Title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. Condition As part of our testing of 27 students who received FSEOG funds, we noted one (1) instance for which the University did not pay the credit balance to the student within the 14 days required. Cause The provisions of Title IV allow the University to collect debts between terms through transfers during the academic year up to an amount of $200.00. In this case, the Fajardo Campus personnel attempted to collect a prior term debt from a student with an available credit balance; however, an incorrect code was inadvertently used in this transaction. Therefore, the remaining credit balance did not get paid within the 14 days as required by Title IV. Effect As a result of this instance of noncompliance, the USDE may issue warnings and/or impose penalties on the University. Questioned Costs None. Context Of the 6,423 students who received FSEOG funds from the selected campuses for 2023, we selected 27 students for testing and noted one (1) instance in which the University did not comply with the disbursements to or on behalf of students’ requirements. Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The University should enhance its control procedures to ensure all credit balances in a student’s account are paid directly to the student within the required timeframe. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 68-69.
Corrective Action Plan As a corrective measure, the following will be carried out: 1. A procedure will be documented with instructions for making and completing transfers. 2. Students' transactions that require transfer between academic terms must be handled by the designated Collections staff, completing the entire transaction in the University system. 3. Once the transfer transaction is completed, it must be verified by the Enrollment Manager, ensuring that the debt collection process has been completed in compliance with the provisions of Title IV. 4. At the Central Office, a report with all transfers made during the academic year will be produced to review and monitor the correctness of the transactions.
FAC accepted this audit on March 7, 2023 — management decision was due September 7, 2023.
Finding No. 2022?001 - Special Tests and Provisions - Return of Title IV Funds Federal Program Name Student Financial Assistance Programs Cluster - Federal Pell Grant Program (PELL), AL No. 84.063 Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria According to 34 CFR 668.22(j)(2) for an institution that is not required to take attendance, it must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the: (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e)(5) of this section; (ii) Academic year in which the student withdrew; or (iii) Educational program from which the student withdrew. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all nine (9) students from the selected campuses that failed to earn a passing grade, for a total of sixty-nine (69) students, and noted that for one (1) student, the determination of withdrawal was performed after the required 30 days, as follows: See Schedule of Findings and Questioned Costs for chart/table Cause The San German campus reinstated the student after a withdrawal was processed. At the end of the term, the professor reported an administrative withdrawal (UW) for the student, however, such administrative withdrawal was not properly processed due to the existence of the previous return of Title IV funds record on system. As a result, the return of Title IV funds was not processed on a timely manner. Effect As a result of this instance of noncompliance, the USDE may issue warnings and/or impose penalties on the University. Also, the incorrect return of Title IV funds could limit the students? future eligibility to Title IV funds. Questioned Costs None. Context Of the 2,539 withdrawals from the selected campuses for the year ended June 30, 2022, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all nine (9) students from the selected campuses that failed to earn a passing grade, for a total of sixty-nine (69) students, and noted one (1) instance of noncompliance. Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Pell funds: See Schedule of Findings and Questioned Costs for chart/table Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Direct Loans: See Schedule of Findings and Questioned Costs for chart/table Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2021-002). Recommendation The University San German Campus? management should reinforce its procedures to ensure the identification and timely resolution of instances in which students withdrew without providing notification to the University. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 67-69.
Show full finding ▾Hide full finding ▴Finding No. 2022?001 - Special Tests and Provisions - Return of Title IV Funds Federal Program Name Student Financial Assistance Programs Cluster - Federal Pell Grant Program (PELL), AL No. 84.063 Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria According to 34 CFR 668.22(j)(2) for an institution that is not required to take attendance, it must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the: (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e)(5) of this section; (ii) Academic year in which the student withdrew; or (iii) Educational program from which the student withdrew. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all nine (9) students from the selected campuses that failed to earn a passing grade, for a total of sixty-nine (69) students, and noted that for one (1) student, the determination of withdrawal was performed after the required 30 days, as follows: See Schedule of Findings and Questioned Costs for chart/table Cause The San German campus reinstated the student after a withdrawal was processed. At the end of the term, the professor reported an administrative withdrawal (UW) for the student, however, such administrative withdrawal was not properly processed due to the existence of the previous return of Title IV funds record on system. As a result, the return of Title IV funds was not processed on a timely manner. Effect As a result of this instance of noncompliance, the USDE may issue warnings and/or impose penalties on the University. Also, the incorrect return of Title IV funds could limit the students? future eligibility to Title IV funds. Questioned Costs None. Context Of the 2,539 withdrawals from the selected campuses for the year ended June 30, 2022, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all nine (9) students from the selected campuses that failed to earn a passing grade, for a total of sixty-nine (69) students, and noted one (1) instance of noncompliance. Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Pell funds: See Schedule of Findings and Questioned Costs for chart/table Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Direct Loans: See Schedule of Findings and Questioned Costs for chart/table Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2021-002). Recommendation The University San German Campus? management should reinforce its procedures to ensure the identification and timely resolution of instances in which students withdrew without providing notification to the University. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 67-69.
R2T4 Late Return Student Jean Morales Cruz; ID #E00542118; Term 2022-10 Cause This is an exceptional case where the student reinstalled the enrollment after a withdrawal process was processed. ? Student enrolled in course CMEM 0291, Section 51806 (EMS Internship) for a total of de 9 credits at the beginning of term 202210. ? On September 7, 2021, the professor indicated that the student had not been attending the course and a total withdrawal was processed, since this was the only course in which student was enrolled for the term. ? The R2T4 calculation was performed and the TIV award cancelled. ? Subsequently, on September 29, the Registrar's office received a certification of the student's attendance to the course and the student's enrollment was reinstalled and the financial aid re awarded. ? Upon finalizing the term, the professor annotated an administrative withdrawal (UW) for the student with the last date of attendance as of October 18, 2021. But the administrative withdrawal was not properly recorded due to previous R2T4 existing record on system and the TIV return not processed on a timely manner. Action Once the circumstances of this case were identified, the R2T4 was reprocessed on June 22, 2022 and the corresponding return of the 50% of the award was completed. Corrective Action Plan The San German campus established a procedure to reinforce the internal communication between the corresponding offices to ensure a proper process for any enrollment reinstalled after an R2T4 process was performed for the same period. 1. The Dean of Academic Affairs receives and signs the student's request for re enrollment in courses. He will submit the request to the Enrollment Manager for the reinstallation process. 2. The Enrollment Manager will evaluate the request and upon approval will run the RWOTIVE- Automatic Registration Reinstatement process. This process will cancel the previous student's withdrawal record, the financial aid adjustment and register the adjustments to the student's account. 3. Once these steps are completed, the Enrollment Manager will notify the Registrar to change the enrollment status in the system and reinstall the courses. 4. Once the Registrar has completed the process, the Bursars Office will validate the total enrollment costs and the Financial Aid Office will be notified for the processing of the financial aid. Also, the Institutional Financial Aid Office designed the report SWOBJAC (Reinstalled Students with Active Total Withdrawal) to identify any student who reinstalled enrollment and an existing R2T4 record is active in our system for the same period. The report will be generated automatically at the end of each week and sent to the Enrollment Manager to identify any pending case. Contact persons: Mrs. Vilma S. Martinez Acting Chancellor San German Campus Mrs. Glenda Diaz Maldonado Institutional Financial Aid Director
2021-002
Finding No. 2022?002 - Special Tests and Provisions ? Enrollment Reporting Federal Program Name Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2) states that unless 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; 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 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. Condition As part of our testing of 40 students who graduated and/or withdrew during 2022, we noted one (1) student for which the University did not report to the National Student Loan Data System (NSLDS) the student status change within the required 60 days? period. Cause Late submissions resulted from the length of time required by the University?s administrative procedures for graduated students and/or from discrepancies identified by the National Student Clearinghouse (NSC), in the students? information. Effect As a result of this condition, the USDE was prevented the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Costs None. Context Of the 5,330 status changes from the selected campuses for 2022, we selected 40 students for testing and noted one (1) instance in which the University did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2021-003). Recommendation The University should enhance its control procedures to ensure all enrollment status changes, including graduate students, are timely and accurately reported to NSDLS. Management should reassess the time-frame in which the University submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting time-frame. The University should enhance both electronic and manual procedures to ensure student loan borrower enrollment status changes are timely and accurately reported to NSLDS. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 67-69.
Show full finding ▾Hide full finding ▴Finding No. 2022?002 - Special Tests and Provisions ? Enrollment Reporting Federal Program Name Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2) states that unless 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; 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 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. Condition As part of our testing of 40 students who graduated and/or withdrew during 2022, we noted one (1) student for which the University did not report to the National Student Loan Data System (NSLDS) the student status change within the required 60 days? period. Cause Late submissions resulted from the length of time required by the University?s administrative procedures for graduated students and/or from discrepancies identified by the National Student Clearinghouse (NSC), in the students? information. Effect As a result of this condition, the USDE was prevented the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Costs None. Context Of the 5,330 status changes from the selected campuses for 2022, we selected 40 students for testing and noted one (1) instance in which the University did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2021-003). Recommendation The University should enhance its control procedures to ensure all enrollment status changes, including graduate students, are timely and accurately reported to NSDLS. Management should reassess the time-frame in which the University submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting time-frame. The University should enhance both electronic and manual procedures to ensure student loan borrower enrollment status changes are timely and accurately reported to NSLDS. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 67-69.
Enrollment Reporting Student - Rodriguez Peria, Joan; ID #M00601823; Term 2022-13 Cause The student's Graduated (G) status was not reported to the NSLDS. The student's graduation application was dated December 2, 2021, but was not paid and submitted until February 12, 2022. The student's degree was certified in our Banner system on February 23, 2022. By the certification date, the "Graduate-Only" file transmissions to the Clearinghouse (NSCH) for the 2022-13 term had ceased. Once the file transmission for a term ceases, any cases has to be manually reported at NSLDS. Unfortunately, this case was not reported to NSLDS. Action Once the circumstances of this case were identified, the student's status update to a (G) Graduate in NSLDS has been intended several instances over the past few weeks and is still in process due to problems with the NSLDS modernized website. The Electronic Announcement ID: GENERAL-22-76 reports open issues with the NSLDS modernized website. Corrective Action Plan According to the Graduation Certification Calendar submitted to the registrars, we will develop a monitoring process to identify students certified as graduate past the certification deadline. These students will be referred to the registrars for immediate certification at the NSLDS and to the Management Compliance Office for verification at the NSLDS. Contact persons: Mrs. Patricia Alvarez, Ph. D. Associate Vice President of Academic Affairs Prof. Evelyn Aviles Institutional Director for Academic Affairs and Student Services
2021-003
FAC accepted this audit on March 15, 2022 — management decision was due September 15, 2022.
Finding No. 2021?001 ? Special Tests and Provisions ? Return of Title IV Funds ?Interruptions of study related to Coronavirus (COVID-19) Federal Program Name Student Financial Assistance Programs Cluster: Federal Pell Grant Program (PELL), AL No. 84.063 Federal Direct Student Loans (DL), AL No. 84.268 Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria Section 3508(a)(1) and (2) of the CARES Act establishes the Secretary shall waive the institutional requirement under section 484B of the Higher Education Act of 1965 (20 U.S.C. 1091b) with respect to the amount of grant or loan assistance (other than assistance received under part C of Title IV of such Act) to be returned under such section if a recipient of assistance under title IV of the Higher Education Act of 1965 (20 U.S.C. 1070 et seq.) withdraws from the institution of higher education during the payment period or period of enrollment as a result of a qualifying emergency. The Secretary shall require each institution using a waiver relating to the withdrawal of recipients under this subsection to report the number of such recipients, the amount of grant or loan assistance (other than assistance received under part C of Title IV of such Act) associated with each such recipient, and the total amount of grant or loan assistance (other than assistance received under part C of Title IV of such Act) for which each institution has not returned assistance under Title IV to the Secretary. Also, Guidance for interruptions of study related to Coronavirus (COVID-19) issued on May 15, 2020 and updated as of June 16, 2020, establishes that any institution that moved students from ground-based instruction to distance learning, closed campus housing or other campus facilities, or experienced other interruptions in instruction during a term within the covered period may consider all withdrawals from students enrolled in affected programs during that term to have been the result of circumstances related to the COVID-19 national emergency. For institutions that did not undergo changes in educational delivery or campus operations as a result of the COVID-19 emergency, during a term or payment period within the covered period, the institution will be required to obtain a written attestation (including by email or text messages) from the student explaining why the withdrawal was the result of the COVID-19 emergency. Institutions must also obtain written attestations from students who withdrew from distance education programs, if applicable, explaining why the withdrawal was the result of the COVID-19 emergency. Allowable circumstances include, but are not limited to, illness of the student or family member, need to become a caregiver or first responder, loss of childcare, economic hardship, inability to access wi-fi due to closed facilities, or an increase in work hours as a result of the COVID-19 emergency. Information (which in the judgment of the institution is reliable) provided by the family member of a withdrawn student whom the institution is unable to contact is acceptable for documentation purposes. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, and noted that for twenty-eight (28) students, the University did not obtain a written attestation from the student explaining why the withdrawal was the result of the COVID-19 emergency, as follows: See Schedule of Findings and Questioned Costs for chart/table. As part of our test, we noted that the University performed the return of Title IV calculations and paid, as SFA credit balances to students, the amounts resulting from the calculations to the corresponding students, instead of returning the Title IV funds to the USDE. Cause Since the national emergency due to coronavirus disease (COVID-19) pandemic continued through June 30, 2021, the University?s operations continued to be disrupted, as it was required by the local government authorities to close its campuses and to provide synchronous (2-way) distance education to all students enrolled in ground-based instruction for all payment periods after the COVID-19 emergency commenced and up to the University?s fiscal year end on June 30, 2021. Accordingly, based on the University?s interpretation of the guidance issued by the USDE during May 2020 and its applicability under the University?s specific circumstances, attestation statements were not requested from students who withdrew, dropped-out, or failed to attend to the University for payment periods after the period in which the University moved its students from ground-based instruction to distance learning. Effect As a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, not requesting the attestation statements may result in the incorrect application of the R2T4 waiver to certain students. Questioned Costs Because the original guidance issued in May 2020 was not sufficiently clear as to the applicability of the R2T4 waiver and when it was necessary to obtain the attestation statements, as well as what payment periods may qualify for the waiver, nor did it provide a clear definition of what constituted a disruption, we are unable to determine the amount of questioned costs, if any, that may result form this instance of non-compliance. Furthermore, since all excess funds resulting from the R2T4 calculations were paid to the students as SFA credit balances, the University did not benefit, nor did it retain any of the related Title IV funds. Context Of the 2,005 withdrawals from the selected campuses for the year ended June 30, 2021, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, for testing and noted twenty-eight (28) students for which the University failed to obtain a written attestation from the student explaining why the withdrawal was the result of the COVID-19 emergency. Following is a description of each sample and the population from which the samples were drawn for students that received Pell funds for the year ended June 30, 2021: See Schedule of Findings and Qestioned Costs for table/chart Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation Specific policies and procedures addressing the guidance for interruptions of study related to emergencies should be added to the University?s existing policies and procedures to ensure future compliance with the USDE regulations. In addition, management should consider consulting with USDE personnel on special and/or new guidance issued in connection with the COVID-19 emergency. Views of Responsible Officials and Planned Corrective Actions The University management does not agree with this finding. Refer to the corrective action plan on pages 68-73.
Show full finding ▾Hide full finding ▴Finding No. 2021?001 ? Special Tests and Provisions ? Return of Title IV Funds ?Interruptions of study related to Coronavirus (COVID-19) Federal Program Name Student Financial Assistance Programs Cluster: Federal Pell Grant Program (PELL), AL No. 84.063 Federal Direct Student Loans (DL), AL No. 84.268 Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria Section 3508(a)(1) and (2) of the CARES Act establishes the Secretary shall waive the institutional requirement under section 484B of the Higher Education Act of 1965 (20 U.S.C. 1091b) with respect to the amount of grant or loan assistance (other than assistance received under part C of Title IV of such Act) to be returned under such section if a recipient of assistance under title IV of the Higher Education Act of 1965 (20 U.S.C. 1070 et seq.) withdraws from the institution of higher education during the payment period or period of enrollment as a result of a qualifying emergency. The Secretary shall require each institution using a waiver relating to the withdrawal of recipients under this subsection to report the number of such recipients, the amount of grant or loan assistance (other than assistance received under part C of Title IV of such Act) associated with each such recipient, and the total amount of grant or loan assistance (other than assistance received under part C of Title IV of such Act) for which each institution has not returned assistance under Title IV to the Secretary. Also, Guidance for interruptions of study related to Coronavirus (COVID-19) issued on May 15, 2020 and updated as of June 16, 2020, establishes that any institution that moved students from ground-based instruction to distance learning, closed campus housing or other campus facilities, or experienced other interruptions in instruction during a term within the covered period may consider all withdrawals from students enrolled in affected programs during that term to have been the result of circumstances related to the COVID-19 national emergency. For institutions that did not undergo changes in educational delivery or campus operations as a result of the COVID-19 emergency, during a term or payment period within the covered period, the institution will be required to obtain a written attestation (including by email or text messages) from the student explaining why the withdrawal was the result of the COVID-19 emergency. Institutions must also obtain written attestations from students who withdrew from distance education programs, if applicable, explaining why the withdrawal was the result of the COVID-19 emergency. Allowable circumstances include, but are not limited to, illness of the student or family member, need to become a caregiver or first responder, loss of childcare, economic hardship, inability to access wi-fi due to closed facilities, or an increase in work hours as a result of the COVID-19 emergency. Information (which in the judgment of the institution is reliable) provided by the family member of a withdrawn student whom the institution is unable to contact is acceptable for documentation purposes. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, and noted that for twenty-eight (28) students, the University did not obtain a written attestation from the student explaining why the withdrawal was the result of the COVID-19 emergency, as follows: See Schedule of Findings and Questioned Costs for chart/table. As part of our test, we noted that the University performed the return of Title IV calculations and paid, as SFA credit balances to students, the amounts resulting from the calculations to the corresponding students, instead of returning the Title IV funds to the USDE. Cause Since the national emergency due to coronavirus disease (COVID-19) pandemic continued through June 30, 2021, the University?s operations continued to be disrupted, as it was required by the local government authorities to close its campuses and to provide synchronous (2-way) distance education to all students enrolled in ground-based instruction for all payment periods after the COVID-19 emergency commenced and up to the University?s fiscal year end on June 30, 2021. Accordingly, based on the University?s interpretation of the guidance issued by the USDE during May 2020 and its applicability under the University?s specific circumstances, attestation statements were not requested from students who withdrew, dropped-out, or failed to attend to the University for payment periods after the period in which the University moved its students from ground-based instruction to distance learning. Effect As a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, not requesting the attestation statements may result in the incorrect application of the R2T4 waiver to certain students. Questioned Costs Because the original guidance issued in May 2020 was not sufficiently clear as to the applicability of the R2T4 waiver and when it was necessary to obtain the attestation statements, as well as what payment periods may qualify for the waiver, nor did it provide a clear definition of what constituted a disruption, we are unable to determine the amount of questioned costs, if any, that may result form this instance of non-compliance. Furthermore, since all excess funds resulting from the R2T4 calculations were paid to the students as SFA credit balances, the University did not benefit, nor did it retain any of the related Title IV funds. Context Of the 2,005 withdrawals from the selected campuses for the year ended June 30, 2021, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, for testing and noted twenty-eight (28) students for which the University failed to obtain a written attestation from the student explaining why the withdrawal was the result of the COVID-19 emergency. Following is a description of each sample and the population from which the samples were drawn for students that received Pell funds for the year ended June 30, 2021: See Schedule of Findings and Qestioned Costs for table/chart Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation Specific policies and procedures addressing the guidance for interruptions of study related to emergencies should be added to the University?s existing policies and procedures to ensure future compliance with the USDE regulations. In addition, management should consider consulting with USDE personnel on special and/or new guidance issued in connection with the COVID-19 emergency. Views of Responsible Officials and Planned Corrective Actions The University management does not agree with this finding. Refer to the corrective action plan on pages 68-73.
Inter American University of Puerto Rico Office of the Vice President for Management, Finance and Systemic Services Response to - Finding No. 2021-001-SpecialTests and Provisions - Return of Title IV Funds- Interruption of Study Related to Coronavirus (COVID-19) Management does not agree with the finding No. 2021-001 - Special Tests and Provisions - Return of Title IV Funds ("R2T4")- Interruption of Study Related to Coronavirus (COVID-19). The University correctly applied the approved R2T4 blanket waiver from March 2020 through June 2021 in compliance with federal and state guidelines. During this period, the University had all ground-based instruction interrupted and delivered through distance learning education in accordance with the declared national emergency and the series of Executive Orders issued by the Governor of the Commonwealth of Puerto Rico requiring all academic work to be conducted using distance learning based education. The University's academic programs were granted temporary permission from its accreditor, Middle States Commission on Higher Education ("MSCHE"), and the Puerto Rico Postsecondary Education Board to maintain distance learning coursework in compliance with the aforementioned national emergency and Executive Orders. It is important to mention that the Governor of the Commonwealth of Puerto Rico declared an emergency period following President Trump's emergency declaration. Both the federal government and the Commonwealth established guidelines to maintain the people's wellbeing and safety during the emergency period. In Puerto Rico, the Governor, over a period of three weeks, issued Executive Orders directing people to work off-site for several weeks and mandating that students at schools and universities change from on ground learning to distance learning during the entirety from March 2020 until June 2021. It was not until August 2021, that the Governor of Puerto Rico allowed ground-based education to resume in Puerto Rico. The auditors' interpretation of the CARES Act and further federal guidance appears to relate mainly to two areas: (1) the duration of the waiver, and (2) the exclusion of the Commonwealth of Puerto Rico Executive Orders issued by the Governor as part of the full period of disruption. The University management does not agree with the auditors' interpretations, which subsequently lead to this finding. The U.S. Department of Education ("DOE") published guidance dated May 15, 2020 (updated June 16, 2020) which states: "We updated this Electronic Announcement on June 16, 2020, extending the timeframe for relief from Return of Title IV Funds requirements provided under the CARES Act to periods that include March 13, 2020, or begin between March 13 and the later of December 31 or the last date that the national emergency is in effect. We also clarified that an institution cannot automatically apply CARES Act Return of Title IV Funds relief to all students who withdraw during a payment period or period of enrollment unless a disruption P.O. Box 363255. San Juan, PR 00936-3255. Tel. (787) 766-1912, Ext. 2406. FAX (787) 764 -1653 to instruction occurred during that period." Id. The updated June 16, 2020, guidance also stated that: "Any institution that moved students from ground-based instruction to distance learning, closed campus housing or other campus facilities, or experienced other interruptions in instruction during a term within the covered period may consider all withdrawals from students enrolled in affected programs during that term to have been the result of circumstances related to the COVI0-19 national emergency... " On August 21, 2020, DOE published an update that states: "Except as noted below, the Department is extending the deadline for all flexibilities related to the COVID-19 emergency through the end of the payment period that includes December 31, 2020 or the end of the payment period that includes the end date for the Federally- declared emergency related to COVID-19, whichever occurs later. We outlined the initial flexibilities in Electronic Announcements published on March 5, April 3, May 15, July 9, and July 10, 2020." It also states: "Return of Title IV Funds An institution is not required to return Title IV funds for any student who begins attendance in a payment period or period of enrollment that includes March 13, 2020, or begins between March 13 and the later of December 31 or the last date that the national emergency is in effect, and subsequently withdraws from the period as a result of COV/0-19-related circumstances. Standard term programs must use the payment period, i.e., semester, trimester, or quarter, to calculate returns. Where an institution has opted to use the period of enrollment to calculate its returns for a non-term or non-standard term program, the waiver may apply to a student who begins attendance in a payment period that includes December 31, 2020 or the last date that the national emergency is in effect and withdraws after the conclusion of that payment period but within the applicable period of enrollment." The Department's guidance also included webinars to explain the application of the flexibilities related to the COVID-19. On March 5, 2021 the University participated in the "Federal Update and Coming Attractions" webinar offered by a Program Specialist of the Minority-Serving and Under-Resourced School Division (MSURSD) invited by the Puerto Rico Association of Financial Aid Administrators (PRASFAA). During the presentation the MSURSD's official clarified that if the institution was forced to change the educational delivery method from ground-based to distance education, all the withdrawals are eligible to be related to COVID-19 (blanket waiver). Also stated that the blanket waiver application for all the withdrawals, was an institution's decision. A recorded webinar is available for reference. The auditors' interpretation of "disruption to instruction" relates to the period when the emergency was initially declared on March 2020 up to June 2020; where all students moved from ground-based instruction to distance learning. Management does not agree with this interpretation since the Governor's mandates kept all ground-based programs on distance learning. This decision wasn't optional for the University; thus, establishing an ongoing, continuous state of disruption to instruction on the island until July 2021 when the Governor allowed on-ground instruction at local campuses to resume. The University followed the guidance and instructions as set forth by both the federal and Commonwealth jurisdictions. As such, Management recognizes that The "Supremacy Clause" applies in this case, which is a clause within "Article VI" of the U.S. Constitution that dictates that federal law is the "supreme law of the land." But in the absence of federal law, or when a state law would provide more protection for consumers, employees, and other residents than what is available under existing federal law, state law holds. The Puerto Rico's Governor executive orders were stricter than the federal government, thereby requiring the University to keep students on distance learning and maintaining a state of disruption from ground-based learning. Indeed, the auditors in their finding even recognize that the DOE's guidance "was not sufficiently clear as to the applicability of the R2T4 waiver" and acknowledged "nor did [the DOE's guidance] provide a clear definition of what constituted a disruption." (see Questioned Costs) In summary, the University correctly interpreted and applied the R2T4 waiver of return of Title IV funds based on DOE's guidance to the period of the national emergency that began March 13, 2020, and that continued through June 2021. The disruption to instruction from in-person learning to distance education continued during this entire period while the Governor's orders and the national emergency were in effect. As per the updated June 16, 2020 guidance, the continuous disruption to the University's students also included the students' housing and campus facilities. Funds were paid directly to students following the DOE's guidance, considering the students faced interruption in educational delivery resulting from the COVID- 19 pandemic. Therefore, the University acted in good faith with the purpose of assisting students during the declared national emergency that, as of today, is still ongoing. For the online programs that did not undergo changes in educational delivery as a result of the COVID-19 emergency, the institution required a written attestation from the student to determine if the withdrawal was the result of the COVID-19 emergency, as per DOE's guidance. Since the University was allowed to resume its ground-based education on August 2021; any R2T4 calculations have been and will be treated using the guidelines for the return of Title IV funds to the Department of Education. The University processes were consistently applied before and during the fiscal year under audit.
Finding No. 2021?002 - Special Tests and Provisions - Return of Title IV Funds Federal Program Name Student Financial Assistance Programs Cluster - Federal Pell Grant Program (PELL), AL No. 84.063 Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria According to 34 CFR 668.22(j)(2) for an institution that is not required to take attendance, it must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the: (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e)(5) of this section; (ii) Academic year in which the student withdrew; or (iii) Educational program from which the student withdrew. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all fourteen (14) students from the selected campuses that failed to earn a passing grade, for a total of seventy-four (74) students, and noted that for one (1) student, the determination of withdrawal was performed after the required 30 days, as follows: See Schedule of Findings and Questioned Costs for chart/table Cause This instance of noncompliance was noted by the University as part of its monitoring procedures. The student was originally identified as a student that failed to earn a passing grade (without professor?s certification), instead of a withdrawal, which the University corrected, however, the University was unable to submit the R2T4 form within 30 days from the actual withdrawal date. Effect As a result of this instance of noncompliance, the USDE may issue warnings and/or impose penalties on the University. Also, the incorrect return of Title IV funds could limit the students? future eligibility to Title IV funds. Questioned Costs None. Context Of the 2,005 withdrawals from the selected campuses for the year ended June 30, 2021, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all fourteen (14) students from the selected campuses that failed to earn a passing grade, for a total of seventy-four (74) students, and noted one (1) instance of noncompliance. Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Pell funds: See Schedule of Findings and Questioned Costs for chart/table Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The University Metro Campus? management should reinforce its procedures to ensure the identification and timely resolution of instances in which students withdrew without providing notification to the University. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 68-73.
Show full finding ▾Hide full finding ▴Finding No. 2021?002 - Special Tests and Provisions - Return of Title IV Funds Federal Program Name Student Financial Assistance Programs Cluster - Federal Pell Grant Program (PELL), AL No. 84.063 Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria According to 34 CFR 668.22(j)(2) for an institution that is not required to take attendance, it must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the: (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e)(5) of this section; (ii) Academic year in which the student withdrew; or (iii) Educational program from which the student withdrew. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all fourteen (14) students from the selected campuses that failed to earn a passing grade, for a total of seventy-four (74) students, and noted that for one (1) student, the determination of withdrawal was performed after the required 30 days, as follows: See Schedule of Findings and Questioned Costs for chart/table Cause This instance of noncompliance was noted by the University as part of its monitoring procedures. The student was originally identified as a student that failed to earn a passing grade (without professor?s certification), instead of a withdrawal, which the University corrected, however, the University was unable to submit the R2T4 form within 30 days from the actual withdrawal date. Effect As a result of this instance of noncompliance, the USDE may issue warnings and/or impose penalties on the University. Also, the incorrect return of Title IV funds could limit the students? future eligibility to Title IV funds. Questioned Costs None. Context Of the 2,005 withdrawals from the selected campuses for the year ended June 30, 2021, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all fourteen (14) students from the selected campuses that failed to earn a passing grade, for a total of seventy-four (74) students, and noted one (1) instance of noncompliance. Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Pell funds: See Schedule of Findings and Questioned Costs for chart/table Identification of a Repeat Finding This is not a repeat finding from the immediate previous audit. Recommendation The University Metro Campus? management should reinforce its procedures to ensure the identification and timely resolution of instances in which students withdrew without providing notification to the University. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 68-73.
Finding No. 2021-002 Special Tests and Provisions - Return of Title IV Fund Metropolitan Campus The Chancellor holds a faculty meeting at the beginning of each academic year to review the processes related to AW's, UW's and certified F's and the importance of acting in a timely manner in relation to these issues. However, considering that during the 2021-13 academic term faculty were working remotely due to the COVID-19 pandemic, communication was difficult. Therefore, to ensure that all faculty participate in the orientation meetings, even during an emergency when they are working remotely, from now on the meetings will be transmitted and recorded through Blackboard Collaborate, and faculty will have to certify their participation in the orientation. Recordings will be available for the faculty that did not participate in the live meeting or want to review the content. Furthermore, the dean of academic affairs and chairs of the academic departments are available during the final grading period to answer questions and clarify doubts concerning final grades and administrative annotations. The Campus assigns a monitor to follow up this process in coordination with the registrar. At the end of each academic term the System Informatics and Telecommunications Center generates and sends to the Enrollment Manager and the Academic Dean a report that provides information about all AW's, UW's and uncertified F's that are possible total withdrawals. The Enrollment Manager will assure that faculty members receive this information immediately and make the necessary corrections within 10 calendar days, from the day following the last day for entering grades. To validate that suspicious grade entries have been reviewed and corrected within five (5) calendar days after the deadline of ten (10) calendar days for the review and correction of suspicious records, the Enrollment Manager will request a report from the Management Compliance Office to confirm that all transactions have been completed. Contact Persons: Mrs. Glenda Diaz Maldonado Institutional Financial Aid Director Mrs. Marilina Wayland Chancellor Metropolitan Campus
Finding No. 2021?003 - Special Tests and Provisions ? Enrollment Reporting Federal Program Name Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/ACriteria 34 CFR 685.309 (b)(2) states that unless 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; 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 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. Condition As part of our testing of 40 students who graduated and/or withdrew during 2021, we noted three (3) students for which the University did not report to the National Student Loan Data System (NSLDS) the student status change within the required 60 days? period. Cause Late submissions resulted from the length of time required by the University?s administrative procedures for graduated students and/or from discrepancies identified by the National Student Clearinghouse (NSC), in the students? information. Effect As a result of this condition, the USDE was prevented the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Costs None. Context Of the 4,907 status changes from the selected campuses for 2021, we selected 40 students for testing and noted three (3) instances in which the University did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2020-002). Recommendation The University should enhance its control procedures to ensure all enrollment status changes, including graduate students, are timely and accurately reported to NSDLS. Management should reassess the time-frame in which the University submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting time-frame. The University should enhance both electronic and manual procedures to ensure student loan borrower enrollment status changes are timely and accurately reported to NSLDS. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 68-73.
Show full finding ▾Hide full finding ▴Finding No. 2021?003 - Special Tests and Provisions ? Enrollment Reporting Federal Program Name Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/ACriteria 34 CFR 685.309 (b)(2) states that unless 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; 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 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. Condition As part of our testing of 40 students who graduated and/or withdrew during 2021, we noted three (3) students for which the University did not report to the National Student Loan Data System (NSLDS) the student status change within the required 60 days? period. Cause Late submissions resulted from the length of time required by the University?s administrative procedures for graduated students and/or from discrepancies identified by the National Student Clearinghouse (NSC), in the students? information. Effect As a result of this condition, the USDE was prevented the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Costs None. Context Of the 4,907 status changes from the selected campuses for 2021, we selected 40 students for testing and noted three (3) instances in which the University did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2020-002). Recommendation The University should enhance its control procedures to ensure all enrollment status changes, including graduate students, are timely and accurately reported to NSDLS. Management should reassess the time-frame in which the University submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting time-frame. The University should enhance both electronic and manual procedures to ensure student loan borrower enrollment status changes are timely and accurately reported to NSLDS. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 68-73.
Finding No. 2021-003 Special Tests and Provisions - Enrollment Reporting Corrective action in cases of students not reported as graduated 1. We will continue to reiterate to the registrars the importance of checking on a monthly basis the error files that the National Student Clearinghouse uploads to the portal and taking immediate action to correct them. Corrective action in cases of students certified as graduated and reported late NSLDS Enrollment Reporting Guide (ed.gov), Page 22 Part of the paragraph "...it is not required that the update be received by NSLDS within two months of the Enrollment Status Effective Date; rather, the school must report the status change in its next scheduled enrollment submission, although this might happen months after the actual effective date. For example, a school may not be aware a student has withdrawn until sometime after the student stops attending. Or, a student may complete the coursework for a degree, but it takes the school time to determine whether the student meets all graduation requirements, and then the school would use an Effective Date backdated to the date the school assigns for graduation. Even though a school may not be able to report a status change until more than two months after the actual Effective Date of that status change, this retroactive reporting does not violate the requirement to report every 60 days." 1. We will design an official form for each academic unit to certify that the degree certification process has been completed as stipulated in the corresponding calendar (Academic Degree Certification Calendar). This form will be signed by the registrar and the chief executive officer of the academic unit. 2. We will continue to reiterate to the registrars the importance of complying with the Academic Degree Certification Calendar deadlines. 3. Near the deadline for completing the Academic Degree Certification Calendar, a reminder will be sent to the chief executive officer and the enrollment manager for follow-up. Corrective action in cases of students not reported as withdrawn and students not reported as withdrawn at the Program Level 1. We will continue to reiterate to the registrars the importance of checking on a monthly basis the error files that the National Student Clearinghouse uploads to the portal and taking immediate action to correct them. 2. A monthly reminder will be sent to the registrar and enrollment manager to make the corresponding corrections of student records listed in the National Student Clearinghouse error files. 3. We will design an official form for each academic unit to certify that the monthly corrections of error files has been completed. This form will be signed by the registrar and enrollment manager of the academic unit. 4. We will select several cases each term to confirm whether the status has been updated on the NSLDS portal. Contact Persons: Mrs. Patricia Alvarez, Ph. D. Associate Vice President of Academic Affairs Prof. Evelyn Aviles Institutional Director for Academic Affairs and Student Services
2020-002
FAC accepted this audit on March 7, 2021 — management decision was due September 7, 2021.
Finding No. 2020?001 - Special Tests and Provisions - Return of Title IV Funds Federal Program Name - Federal Pell Grant Program (PELL), CFDA No. 84.063 Name of Federal Agency - U.S. Department of Education (USDE) Pass-through Entity - N/A Criteria 34 CFR 668.173(b) states that an institution returns unearned Title IV, HEA, program funds timely if; (1) the institution deposits or transfers the funds into the bank account it maintains under ?668.163 no later than 45 days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower's loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all five (5) students from the selected campuses that failed to earn a passing grade, for a total of sixty-five (65) students, and noted the following instances of noncompliance: For three (3) students, the return of Title IV funds was performed after the required 45 days, as follows: See Schedule of Findings and Questioned Costs for chart/table. Cause For the first student, the Metro campus did not cancel one of the courses in which the student was enrolled in a timely manner, accordingly, at the date of the actual withdrawal, the student continued to be classified as active. For the second student, the Bayamon Campus returned funds based on the Time Student Status for a full-time student, instead of a half-time student, as was applicable for this student. For the third student, the San German campus originally entered the incorrect amount of the grant awards received by the student. The grant amount and related return of Title IV funds were corrected prior to year end. At the time of the error, the San German campus was operating within a federally declared disaster zone due to several earthquakes, which resulted in power outages and limitations on certain services. Effect As a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. Also, the incorrect return of Title IV funds could limit the students? future eligibility to Title IV funds. Questioned Costs None. Context Of the 2,540 withdrawals from the selected campuses for the year ended June 30, 2020, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all five (5) students from the selected campuses that failed to earn a passing grade, for a total of sixty-five (65) students, and noted three (3) instances of noncompliance. Following is a description of the sample that included the findings identified and the population from which the sample was drawn for students that received Pell funds: See Schedule of Findings and Questioned Costs for chart/table. Following is a description of the sample that included the findings identified and the population from which the sample was drawn for students that received Direct Loans: See Schedule of Findings and Questioned Costs for chart/table. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2019-002). Recommendation The Metro Campus should continue to improve its processes and procedures to ensure that the cancellation of courses is made in a timely manner to properly reflect the student?s status at the time of withdrawal. The Bayamon Campus should continue to improve its processes and procedures to ensure the use of the correct Time Student Status when the Return of Title IV funds is made. The San German campus should continue to improve its processes and procedures to ensure that the Return of Title IV funds is made using the correct information and errors, if any, are identified and corrected in a timely manner Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 66-68.
Show full finding ▾Hide full finding ▴Finding No. 2020?001 - Special Tests and Provisions - Return of Title IV Funds Federal Program Name - Federal Pell Grant Program (PELL), CFDA No. 84.063 Name of Federal Agency - U.S. Department of Education (USDE) Pass-through Entity - N/A Criteria 34 CFR 668.173(b) states that an institution returns unearned Title IV, HEA, program funds timely if; (1) the institution deposits or transfers the funds into the bank account it maintains under ?668.163 no later than 45 days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower's loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all five (5) students from the selected campuses that failed to earn a passing grade, for a total of sixty-five (65) students, and noted the following instances of noncompliance: For three (3) students, the return of Title IV funds was performed after the required 45 days, as follows: See Schedule of Findings and Questioned Costs for chart/table. Cause For the first student, the Metro campus did not cancel one of the courses in which the student was enrolled in a timely manner, accordingly, at the date of the actual withdrawal, the student continued to be classified as active. For the second student, the Bayamon Campus returned funds based on the Time Student Status for a full-time student, instead of a half-time student, as was applicable for this student. For the third student, the San German campus originally entered the incorrect amount of the grant awards received by the student. The grant amount and related return of Title IV funds were corrected prior to year end. At the time of the error, the San German campus was operating within a federally declared disaster zone due to several earthquakes, which resulted in power outages and limitations on certain services. Effect As a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. Also, the incorrect return of Title IV funds could limit the students? future eligibility to Title IV funds. Questioned Costs None. Context Of the 2,540 withdrawals from the selected campuses for the year ended June 30, 2020, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all five (5) students from the selected campuses that failed to earn a passing grade, for a total of sixty-five (65) students, and noted three (3) instances of noncompliance. Following is a description of the sample that included the findings identified and the population from which the sample was drawn for students that received Pell funds: See Schedule of Findings and Questioned Costs for chart/table. Following is a description of the sample that included the findings identified and the population from which the sample was drawn for students that received Direct Loans: See Schedule of Findings and Questioned Costs for chart/table. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2019-002). Recommendation The Metro Campus should continue to improve its processes and procedures to ensure that the cancellation of courses is made in a timely manner to properly reflect the student?s status at the time of withdrawal. The Bayamon Campus should continue to improve its processes and procedures to ensure the use of the correct Time Student Status when the Return of Title IV funds is made. The San German campus should continue to improve its processes and procedures to ensure that the Return of Title IV funds is made using the correct information and errors, if any, are identified and corrected in a timely manner Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 66-68.
Finding No. 2020-001 ? Special Tests and Provisions ? Return of Title IV Funds The return of Title IV funds corrective action plans is presented by campus based on the nature of each instance. Bayamon Campus At the Bayamon campus, an additional set of procedures is designed to identify and prevent the possibility of the occurrence of an incorrect post withdrawal calculation and for managing the cases within the 45 days required for the return funds. The procedure includes weekly interactions to work on the cases that are detected as total withdrawals; and two additional control level, which incorporate a procedure to follow-up on the cases pending correction and a monthly report with Enrollment Manager certification. The detailed procedure is described herein: ? Registrar will generate weekly the total withdrawals report. The cases will be reviewed to assure the correct application of withdrawal codes. In case of detecting incorrect codes, it will proceed to correct them. Verified report will be referred to the Director of Financial Assistance and to the Bursar Director. ? Weekly the Director of Financial Assistance and the Bursar Director will meet to work and produce the ?Treatment of Title IV Funds When the Student Withdraws from a Credit Hour Program? document. The Bursar Director will produce a report to ensure the applied costs for each case are correct. ? Bursar Director will maintain records of cases, updated weekly. This record will contain status of each cases and comments, when necessary. Also, contains a flag, which it is necessary to work some additional processes and will be available on a common platform, so that any authorized personnel can access it. The Director of Financial Aid will act promptly over identified records. ? At the end of each month, the Registrar will produce the total withdrawals report including all the withdrawals and will verify that these three reports (Records maintained by Bursar Office, Total withdrawals report, and the Treatment of Title IV Funds When the Student Withdraws from a Credit Hour Program report) are in accordance. ? Monthly cases status report will be sent to Enrollment Manager to certify that cases were processed accordingly. Contact persons: Mrs. Glenda Diaz Maldonado Institutional Financial Aid Director Dr. Carlos Olivares, Ph.D Bayamon Campus Chancellor Metropolitan Campus In the case of student subject of the finding, the total withdrawal was processed adequately within the offices of Enrollment Management, for the total amount of twelve credits at the date of the official withdrawal. The amount of Pell Grant was calculated correctly for the period for which the student was enrolled. However, this did not occur within the 45 days required period due to the fact that a section remained active when it should have been cancelled. In order to ensure that courses that need to be cancelled do not remain active during any specific term, a report will be produced by the Dean of Academic Affairs that includes all active sections that do not contain all the official information, such as, professor name, schedule, location and students enrolled, during the first 30 days of the beginning of the term. This will allow department chairs to make corrections, verify and cancel all sections that should not remain active. The Dean of Academic Affairs will produce the report and certify that all corrections were made by the departments? chairs. The Chancellor instructed department chairs and academic deans about this procedure and the importance of its compliance, so that no section that should has been cancelled remain active. On September 14, a written communication was sent by the Chancellor to deans and department chairs, establishing responsibilities of departments? chairs in the management of all sections, especially those that remained active so that they include all the necessary information, and also verify that all sections that should not be active have been cancelled. Academic deans were instructed to certify to the dean of Academic Affairs that all active sections are correct and that the cancellation of sections that are not offered was completed. This needs to be done after the third week of classes. All these instructions were effective immediately. Contact persons: Mrs. Glenda Diaz Maldonado Institutional Financial Aid Director Mrs. Marilina Wayland Metropolitan Campus Chancellor San German Campus To prevent cases from being processed late, the following corrective actions will be carried out: ? Registrar?s Office ? The Registrar will activate or deactivate the original charges indicator so that the computation or of the Return of Title IV funds is carried out correctly. ? Bursar?s Office ? The Bursar will verify for each case the original charges and the corresponding indicator, to compute the reimbursement or return of Title IV funds, if applicable. Those cases that require financial aid adjustment will be handed over on the same day to the Financial Aid Director in person. ? Financial Aid Office ? The Director of Financial Aid, will receive those cases requiring financial aid revision before the system performs the calculation of reimbursement for total withdrawals and will make the corresponding adjustments so that the return of funds is processed correctly and on a timely manner. The Director of Financial Aid will request the Institutional Financial Aid Office to generate the file corresponding to COD so the withdrawals meet the 45-day deadline established by the Federal Regulations. An additional officer from the Bursar's Office will be assigned to verify the withdrawals. As additional information, the San German Campus operations were impacted during the month of January 2020 with a series of earthquake events that occurred in the southeast area of Puerto Rico where the campus is located. These caused disruption on the electric service and limitation on administrative services. The Official DR-4473 disaster declaration date was January 16, 2020. Contact persons: Mrs. Glenda Diaz Maldonado Institutional Financial Aid Director Mrs. Agnes Mojica San German Campus Chancellor
2019-002
Finding No. 2020?002 - Special Tests and Provisions ? Enrollment Reporting Federal Program Name - Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency - U.S. Department of Education Pass-through Entity - N/A Criteria 34 CFR 685.309 (b)(2) states that unless 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; 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 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. Condition As part of our testing of 40 students who graduated and/or withdrew during 2020, we noted five (5) students for which the University did not report to the National Student Loan Data System (NSLDS) the student status change within the required 60 days? period. Cause Late submissions resulted from the length of time required by the University?s administrative procedures for graduated students and/or from differences between the NSLDS schedule of transmissions and the registrar?s office calendar for submissions. Effect As a result of this condition, the USDE was prevented the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Costs None Context Of the 5,228 status changes from the selected campuses for 2020, we selected 40 students for testing and noted five (5) instances in which the University did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2019-001). Recommendation Procedures should be implemented to ensure the NSLDS schedule of transmissions and the registrar?s office calendar for submissions are consistent and comply with the required reporting time-frame. In addition, the University should enhance its control procedures to ensure all enrollment status changes, including graduate students, are timely and accurately reported to NSDLS. Management should reassess the time-frame in which the University submits the information to the National Student Clearinghouse (NSC) and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting time-frame. The University should enhance both electronic and manual procedures to ensure student loan borrower enrollment status changes are timely and accurately reported to NSLDS. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 66-68.
Show full finding ▾Hide full finding ▴Finding No. 2020?002 - Special Tests and Provisions ? Enrollment Reporting Federal Program Name - Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency - U.S. Department of Education Pass-through Entity - N/A Criteria 34 CFR 685.309 (b)(2) states that unless 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; 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 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. Condition As part of our testing of 40 students who graduated and/or withdrew during 2020, we noted five (5) students for which the University did not report to the National Student Loan Data System (NSLDS) the student status change within the required 60 days? period. Cause Late submissions resulted from the length of time required by the University?s administrative procedures for graduated students and/or from differences between the NSLDS schedule of transmissions and the registrar?s office calendar for submissions. Effect As a result of this condition, the USDE was prevented the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Costs None Context Of the 5,228 status changes from the selected campuses for 2020, we selected 40 students for testing and noted five (5) instances in which the University did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2019-001). Recommendation Procedures should be implemented to ensure the NSLDS schedule of transmissions and the registrar?s office calendar for submissions are consistent and comply with the required reporting time-frame. In addition, the University should enhance its control procedures to ensure all enrollment status changes, including graduate students, are timely and accurately reported to NSDLS. Management should reassess the time-frame in which the University submits the information to the National Student Clearinghouse (NSC) and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting time-frame. The University should enhance both electronic and manual procedures to ensure student loan borrower enrollment status changes are timely and accurately reported to NSLDS. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 66-68.
Finding No. 2020-002 ? Special Tests and Provisions ? Enrollment Reporting Corrective action in cases of students certified as graduated and reported late: 1. We will continue to reiterate to the registrars the importance of complying with the Degree Certification Calendar deadlines. 2. We will send periodic written reminders to the registrars of the steps to certify graduate status at the NSLDS and National Student Clearinghouse in the cases of students with incomplete grades or past the deadline for certifying degrees. 3. We will select several cases each term to confirm whether the status has been updated at the NSLDS. Corrective action in cases of students not reported as Withdrawn: 1.We will continue to reiterate to the registrars the importance of checking on a monthly basis the error files that the National Student Clearinghouse uploads to the portal and taking immediate action to correct them. 2. We will select several cases each term to confirm whether the status has been updated at the NSLDS. Contact persons: Ms. Patricia Alvarez, Ph.D. Associate Vice President of Academic Affairs Prof. Evelyn Aviles Institutional Director for Academic Affairs and Student Services
2019-001
FAC accepted this audit on February 5, 2020 — management decision was due August 5, 2020.
Finding No. 2019?001 - Special Tests and Provisions ? Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless 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; 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 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. Condition As part of our testing of 40 students who graduated and/or withdrew during 2019, we noted the following instances of non-compliance: 1. Two (2) students for which the University did not report to the National Student Loan Data System (NSLDS) the student status change within the required 60 days? period. 2. Five (5) students for which the University did not report the student status changes to the NSLDS. Cause Late submissions resulted from the length of time required by the University?s administrative procedures for graduated students and/or from differences between the NSLDS schedule of transmissions and the registrar?s office calendar for submissions. Unreported status changes were due to oversights. Effect As a result of this condition, the USDE was prevented the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Costs None Context Of the 4,343 status changes from the selected campuses for 2019, we selected 40 students for testing and noted 7 instances in which the University did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2018-003). Recommendation Procedures should be implemented to ensure the NSLDS schedule of transmissions and the registrar?s office calendar for submissions are consistent and comply with the required reporting time-frame. In addition, the University should enhance its control procedures to ensure all enrollment status changes, including graduate students, are timely and accurately reported to NSDLS. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on page 63.
Show full finding ▾Hide full finding ▴Finding No. 2019?001 - Special Tests and Provisions ? Enrollment Reporting Federal Program Name Federal Pell Grant Program (PELL), CFDA No. 84.063 Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2)(ii) states that unless 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; 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 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. Condition As part of our testing of 40 students who graduated and/or withdrew during 2019, we noted the following instances of non-compliance: 1. Two (2) students for which the University did not report to the National Student Loan Data System (NSLDS) the student status change within the required 60 days? period. 2. Five (5) students for which the University did not report the student status changes to the NSLDS. Cause Late submissions resulted from the length of time required by the University?s administrative procedures for graduated students and/or from differences between the NSLDS schedule of transmissions and the registrar?s office calendar for submissions. Unreported status changes were due to oversights. Effect As a result of this condition, the USDE was prevented the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Costs None Context Of the 4,343 status changes from the selected campuses for 2019, we selected 40 students for testing and noted 7 instances in which the University did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2018-003). Recommendation Procedures should be implemented to ensure the NSLDS schedule of transmissions and the registrar?s office calendar for submissions are consistent and comply with the required reporting time-frame. In addition, the University should enhance its control procedures to ensure all enrollment status changes, including graduate students, are timely and accurately reported to NSDLS. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on page 63.
Finding No. 2019-001 ? Special Tests and Provisions ? Enrollment Reporting Name of Contact Person: Ms. Patricia Alvarez, Ph.D. Associate Vice President of Academic Affairs Prof. Evelyn Aviles Institutional Director for Academic Affairs and Student Services Corrective Action: To ensure that enrollment status changes are timely and accurately reported to NSDLS, the Vice Presidency for Academic and Student Affairs will take the following corrective actions: a. The files of the cases rejected by the National Student Clearinghouse (G-DV) will be downloaded and the cases with multiple active records enclosed in the National Student Clearinghouse will be reviewed more promptly. To minimize the multiplicity of records in the National Student Clearinghouse, the ?Centro de Informatica y Telecomunicaciones? will prepare a report that generates a file of students certified as graduates (Graduates Only File) in order to send it to the National Student Clearinghouse two days before each transmission of the Degree Verify. b. Written and periodic notifications about the importance of reviewing cases rejected by the National Student Clearinghouse will be sent to the registrars. c. Adjustments were made to the transmission schedules of Enrollment Reporting to incorporate the summer term (July) and other non-required terms.
2018-003
Finding No. 2019?002 - Special Tests and Provisions - Return of Title IV Funds Federal Program Name Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria 34 CFR 668.173(b) states that an institution returns unearned Title IV, HEA, program funds timely if; (1) the institution deposits or transfers the funds into the bank account it maintains under ? 668.163 no later than forty-five (45) days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer (EFT) no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower's loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all four (4) students from the selected campuses that failed to earn a passing grade, for a total of sixty-four (64) students, and noted the following instance of noncompliance: For one (1) student, the return of Title IV funds was performed after the required 45 days as follows: See Schedule of Findings and Questioned Costs for chart/table. Cause The withdrawal date used by the registrar?s office of the San German campus was not the actual date when the withdrawal process began. Also, the financial aid officer of the San German campus failed to enter the corresponding adjustment to the information system to process the refund of Title IV funds on a timely manner, resulting in the late return noted. Effect As a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. Questioned Costs None. Context Of the 2,437 withdrawals from the selected campuses for the year ended June 30, 2019, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all four (4) students from the selected campuses that failed to earn a passing grade, for a total of sixty-four (64) students, and noted one (1) instance of noncompliance. Following is a description of each sample and the population from which the samples were drawn for students that received Pell funds for the year ended June 30, 2019: See Schedule of Findings and Questioned Costs for chart/table. Following is a description of each sample and the population from which the samples were drawn for students that received Direct Loans funds for the year ended June 30, 2019: See Schedule of Findings and Questioned Costs for chart/table. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2018-002). However, the prior year finding was noted in the Fajardo campus. Recommendation The management of the San German campus should improve its processes and procedures to ensure that the registrar officers enter the correct withdrawal dates. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 63-64.
Show full finding ▾Hide full finding ▴Finding No. 2019?002 - Special Tests and Provisions - Return of Title IV Funds Federal Program Name Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria 34 CFR 668.173(b) states that an institution returns unearned Title IV, HEA, program funds timely if; (1) the institution deposits or transfers the funds into the bank account it maintains under ? 668.163 no later than forty-five (45) days after the date it determines that the student withdrew; (2) The institution initiates an electronic funds transfer (EFT) no later than 45 days after the date it determines that the student withdrew; (3) The institution initiates an electronic transaction, no later than 45 days after the date it determines that the student withdrew, that informs a FFEL lender to adjust the borrower's loan account for the amount returned; or (4) The institution issues a check no later than 45 days after the date it determines that the student withdrew. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all four (4) students from the selected campuses that failed to earn a passing grade, for a total of sixty-four (64) students, and noted the following instance of noncompliance: For one (1) student, the return of Title IV funds was performed after the required 45 days as follows: See Schedule of Findings and Questioned Costs for chart/table. Cause The withdrawal date used by the registrar?s office of the San German campus was not the actual date when the withdrawal process began. Also, the financial aid officer of the San German campus failed to enter the corresponding adjustment to the information system to process the refund of Title IV funds on a timely manner, resulting in the late return noted. Effect As a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. Questioned Costs None. Context Of the 2,437 withdrawals from the selected campuses for the year ended June 30, 2019, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all four (4) students from the selected campuses that failed to earn a passing grade, for a total of sixty-four (64) students, and noted one (1) instance of noncompliance. Following is a description of each sample and the population from which the samples were drawn for students that received Pell funds for the year ended June 30, 2019: See Schedule of Findings and Questioned Costs for chart/table. Following is a description of each sample and the population from which the samples were drawn for students that received Direct Loans funds for the year ended June 30, 2019: See Schedule of Findings and Questioned Costs for chart/table. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2018-002). However, the prior year finding was noted in the Fajardo campus. Recommendation The management of the San German campus should improve its processes and procedures to ensure that the registrar officers enter the correct withdrawal dates. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 63-64.
Finding No. 2019-002 ? Special Tests and Provisions - Return of Title IV Funds Name of Contact Person: Mrs. Frances Martinez Institutional Financial Aid Director Mrs. Agnes Mojica San German Campus Chancellor Corrective Action: The San German Campus Enrollment Management Office will assure the compliance with the current policies and procedures on how to correct a refund and repayment calculation. ? The Registrar?s Office will inform to the Financial Aid Office of any correction done to a total withdrawal transaction on a promptly manner. ? The Financial Aid Office will proceed with the appropriate adjustment to comply within the timeframe established by the regulations. Recurrence of this issue is not expected.
2018-002
FAC accepted this audit on March 14, 2019 — management decision was due September 14, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2017-002
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GSA_MIGRATION
2017-003
FAC accepted this audit on March 12, 2018 — management decision was due September 12, 2018.
GSA_MIGRATION
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2016-001
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2016-002
FAC accepted this audit on January 22, 2017 — management decision was due July 22, 2017.
GSA_MIGRATION
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2015-001
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2015-002
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