EIN: 660349669
UEI: XVQJLM5S8L85
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 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 October 1, 2026 (37 days from today).
What is a management decision? →Finding No. 2025-001 - Special Tests and Provisions – Enrollment Reporting Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education’s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loans Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster is submitted within 60 days. These changes include reductions or increase in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-four (24) students from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended June 30, 2025. As a result of our test, we noted that for one (1) out of twenty-four (24) students that received Student Financial Assistance funds, or 4% of the applicable sample, the University did not report to the NSLDS the students’ status change within the required 60 days’ period. Context Of the one hundred forty-three (146) instances of status changes, we selected twenty-four (24) that had received Student Financial Assistance funds and determined that for one (1) out of twenty-four (24) students that received Student Financial Assistance funds, the University did not comply with the enrollment reporting requirements. Cause Non-compliance was mainly due to human error. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2024-001. Recommendation The University must ascertain that students’ documentation and other information necessary to comply with the federal funds’ enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the time frame required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 58-59.
Show full finding ▾Hide full finding ▴Finding No. 2025-001 - Special Tests and Provisions – Enrollment Reporting Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education’s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loans Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster is submitted within 60 days. These changes include reductions or increase in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-four (24) students from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended June 30, 2025. As a result of our test, we noted that for one (1) out of twenty-four (24) students that received Student Financial Assistance funds, or 4% of the applicable sample, the University did not report to the NSLDS the students’ status change within the required 60 days’ period. Context Of the one hundred forty-three (146) instances of status changes, we selected twenty-four (24) that had received Student Financial Assistance funds and determined that for one (1) out of twenty-four (24) students that received Student Financial Assistance funds, the University did not comply with the enrollment reporting requirements. Cause Non-compliance was mainly due to human error. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2024-001. Recommendation The University must ascertain that students’ documentation and other information necessary to comply with the federal funds’ enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the time frame required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 58-59.
1. Internal Reconciliation & Validation (ECL Protocol) Purpose: Ensure all enrollment status changes are accurate before they are entered into NSLDS. Ensure 100% accurate and timely reporting of all enrollment status changes to NSLDS. Key Actions: Last year, UCC established an Internal Reconciliation and Validation (Enrollment Changes List (ECL) protocol). Through the ECL protocol, at the start of each reporting cycle, the academic programs reviewed and reconciled the NSLDS enrollment list with the active UCC enrollment data within 24 hours. In the protocol, the Registrar certifies the completed list of enrollments, and the Assistant Dean and the Data Manager confirm data accuracy. During the July 2025 NSLDS enrollment reporting cycle, 113 graduations were reported out of the 114 degrees conferred on June 6, 2025. In this reporting cycle, the graduation of one student was not reported promptly due to human error, and the process in place was not effective in detecting the error in that period because data changes were entered in batches of 15 students, and the review process did not recognize that one student (change) was missing. However, through the ECL protocol, the UCC identified, validated, and corrected the mistake in September, during the next NSLDS enrollment reporting cycle. UCC will continue to follow the ECL protocol, but will enhance the oversight of the procedure and increase the validation and review of changes made to the report. Expected Outcome: Accurate, complete, and validated enrollment data before NSLDS reporting. 2. Controlled NSLDS Data Entry & Documentation – New steps Purpose: Ensure NSLDS reporting is accurate and reliable despite system auto-processing. Key actions: Instead of uploading enrollment changes in batches, UCC will enter student enrollment changes into the NSLDS platform on a one-to-one basis. During data entry, the assistant registrar will apply adjustments to NSLD and validate each submission’s status, effective date, and enrollment level after each adjustment. Before the report is submitted, the Registrar will double-check entries in NSLDS against related reports, using the ECL as a reference. UCC began this process for the March 2026 reporting cycle. Expected Outcome: NSLDS entries are traceable, documented, and consistently accurate. 3. Post Submission Quality Assurance (Within 24 Hours) Purpose: Confirm NSLDS accepted entries correctly and identify discrepancies quickly. Key Actions: To prevent omission errors, the Data Manager and the Registrar will conduct a post-submission data quality review of the NSLDS entries within 24 hours. They will compare NSLDS entries against the validated ECL and evidence of submission. The post-submission data quality assurance process will allow the UCC to correct and document any discrepancies immediately. The Data Manager and the Registrar will be able to notify the Assistant Dean for follow‑up and trend monitoring. Expected Outcome: NSLDS records align with institutional data, reducing errors and preventing duplicate audit findings. 4. Restructuring of the Registrar's Office Purpose: Reorganization of the department to increase staff and supervision to attain an enhanced level of compliance with critical reporting areas to comply with USDE-related standards and procedures. Key Actions: New hirings are underway to revamp the department, and training will be provided to ensure that personnel are prepared to process data in accordance with USDE standards. Expected Outcomes: With enhanced staff and supervision, along with the new procedures established, sustained compliance and prevention of repeat findings.
2024-001
FAC accepted this audit on March 29, 2025 — management decision was due September 29, 2025.
Finding No. 2024-001 - Special Tests and Provisions – Enrollment Reporting Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education’s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loans Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-four (24) students from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended June 30, 2024. As a result of our test, we noted that for four (4) out of twenty-four (24) students that received Student Financial Assistance funds, or 17% of the applicable sample, the University did not report to the NSLDS the students’ status change within the required 60 days’ period. Context Of the one hundred forty-three (143) instances of status changes, we selected twenty-four (24) that had received Student Financial Assistance funds and determined that for four (4) out of twenty-four (24) students that received Student Financial Assistance funds, the University did not comply with the enrollment reporting requirements. Cause Non-compliance was mainly due to a lack of proper oversight over this requirement. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2023-001. Recommendation The University must ascertain that students’ documentation and other information necessary to comply with the federal funds’ enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on page 59
Show full finding ▾Hide full finding ▴Finding No. 2024-001 - Special Tests and Provisions – Enrollment Reporting Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education’s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loans Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-four (24) students from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended June 30, 2024. As a result of our test, we noted that for four (4) out of twenty-four (24) students that received Student Financial Assistance funds, or 17% of the applicable sample, the University did not report to the NSLDS the students’ status change within the required 60 days’ period. Context Of the one hundred forty-three (143) instances of status changes, we selected twenty-four (24) that had received Student Financial Assistance funds and determined that for four (4) out of twenty-four (24) students that received Student Financial Assistance funds, the University did not comply with the enrollment reporting requirements. Cause Non-compliance was mainly due to a lack of proper oversight over this requirement. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2023-001. Recommendation The University must ascertain that students’ documentation and other information necessary to comply with the federal funds’ enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on page 59
1. Implement new communication channels to align process to NSLDS and the USDoE. Engage with NSLDS: Requested an access token for the data manager to monitor and reconcile data submitted. Reach out to NSLDS to coordinate new reconciliation reports out of NSLDS database. 2. Training Maintain sustained training and preparation for the staff. 3. Implement a weekly review process to doublecheck the entries for changes in enrollment reporting in NSLDS. Implement a Document Changes and Actions Log: Keep detailed records of all changes made to procedures and actions taken to address the audit findings. This documentation can be useful for future reviews. The Registrar will assure that all changes (LOA, withdrawals, re entries, and reclassifications, completions, graduations) are entered weekly and documented across all databases (NSLDS, Jenzabar student record, SRS, others as applicable).
2023-001
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
Finding No. 2023-001 - Special Tests and Provisions – Enrollment Reporting Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education’s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loan Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-six (26) students from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended June 30, 2023. As a result of our test, we noted that for one (1) out of twenty-five (25) students that received Student Financial Assistance funds, or 4% of the applicable sample, the University did not report to the NSLDS the students’ status change within the required 60 days’ period. Context Of the 94 instances of status changes, we selected twenty-six (26) students (of which, twenty-five (25) had received Student Financial Assistance funds) and determined that for one (1) out of twenty-five (25) students that received Student Financial Assistance funds, the University did not comply with the enrollment reporting requirements. Cause Non-compliance was mainly due to a lack of proper oversight over this requirement. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2022-001. Recommendation The University must ascertain that students’ documentation and other information necessary to comply with the federal funds’ enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 59.
Show full finding ▾Hide full finding ▴Finding No. 2023-001 - Special Tests and Provisions – Enrollment Reporting Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education’s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. A student’s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loan Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-six (26) students from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended June 30, 2023. As a result of our test, we noted that for one (1) out of twenty-five (25) students that received Student Financial Assistance funds, or 4% of the applicable sample, the University did not report to the NSLDS the students’ status change within the required 60 days’ period. Context Of the 94 instances of status changes, we selected twenty-six (26) students (of which, twenty-five (25) had received Student Financial Assistance funds) and determined that for one (1) out of twenty-five (25) students that received Student Financial Assistance funds, the University did not comply with the enrollment reporting requirements. Cause Non-compliance was mainly due to a lack of proper oversight over this requirement. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2022-001. Recommendation The University must ascertain that students’ documentation and other information necessary to comply with the federal funds’ enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 59.
To correct the student reporting process in NSLDS and in addition to the actions already implemented, the following actions will be executed: 1. By June 30, 2024, achieve 100 % accurate reporting by performing a bi-monthly internal reconciliation (July, September, November, January, March, May): a. Bi-monthly the first day of the month of the reporting period, the IEO and Registrar offices will prepare the Enrollment Changes List (ECL). The list will include withdrawals, LOA, graduations, and other enrollment status changes. The ECL will be conciliated with each academic program leader within 24 hours. b. 2 calendar days after (a), the Registrar will certify and sign the list to assure the enrollment status is accurate. c. 3 calendar days after (b), the Registrar Office and IEO will do the data entry in the NSLDS platform. d. 1 calendar days after (c), the reconciled Enrollment Changes List will be revised by the Assistant Dean of Licensing and Accreditation for validation. e. 2 days calendar after (d), the reconciled and validated ECL be revised by Academic Dean and Vice-President for certification of the accurate NSLDS reporting. 2. By June 30, 2024, achieve 100 % of accurate reporting to the NSLDS by continuing the implementation of the monthly process of reconciliation of withdrawals and verification of attendance in the SharePoint. 3. By June 30, 2024, assure quality improvement through re-training of all Registrar Office staff and academic programs leadership in the processes and responsibilities regarding compliance reporting of student status in NSLDS and our internal policies and procedures.
2022-001
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
Finding No. 2022-001 - Special Tests and Provisions ? Enrollment Reporting Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education?s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loan Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-five (25) students from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended June 30, 2022. As a result of our test, we noted that for two (2) out of twenty-three (23) cases that received Student Financial Assistance funds, or 9% of the applicable sample, the University did not report to the NSLDS the students? status changes within the time prescribed by the regulations. In addition, we noted two (2) cases, or 9% of the applicable sample, for which the student?s status was incorrectly reported. We also noted two (2) cases, or 9% of the applicable sample, for which the student?s status was reported late exceeding the sixty (60) days allowed. Context Of the 148 instances of status changes, we selected twenty-five (25) students and determined that for six (6) out of twenty-three (23) cases that received Student Financial Assistance funds, the University did not comply with the enrollment reporting requirements. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2021-001. Recommendation The University must ascertain that students? documentation and other information necessary to comply with the federal funds? enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 66-76.
Show full finding ▾Hide full finding ▴Finding No. 2022-001 - Special Tests and Provisions ? Enrollment Reporting Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education?s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loan Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-five (25) students from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended June 30, 2022. As a result of our test, we noted that for two (2) out of twenty-three (23) cases that received Student Financial Assistance funds, or 9% of the applicable sample, the University did not report to the NSLDS the students? status changes within the time prescribed by the regulations. In addition, we noted two (2) cases, or 9% of the applicable sample, for which the student?s status was incorrectly reported. We also noted two (2) cases, or 9% of the applicable sample, for which the student?s status was reported late exceeding the sixty (60) days allowed. Context Of the 148 instances of status changes, we selected twenty-five (25) students and determined that for six (6) out of twenty-three (23) cases that received Student Financial Assistance funds, the University did not comply with the enrollment reporting requirements. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2021-001. Recommendation The University must ascertain that students? documentation and other information necessary to comply with the federal funds? enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 66-76.
The identified instances were recorded before the university put in place the controls described below. In order to assure compliance with NSLDS reporting requirements, determinations of funds earned, and timing, beginning with academic year 2022-2023 (August-2022) the university is taking the following measures: 1. A MSSharePoint was created in collaboration among the Registrar?s, Financial Aid and Finance Offices staff to serve as an easy access documentation repository and to enhance communication. Information of changes in the enrollment status of any student is documented internally for discussion among the offices (Monthly Withdrawal Conciliation Report). 2. Monthly meetings with the Registrar?s, Financial Aid and Finance Offices staff takes place. Personnel from the Institutional Effectiveness Office, and the Offices of the Dean and the Assistant Dean of Academic Affairs will also attend to facilitate thediscussion. During these meetings the three offices reconcile data on student enrollment status (as documented in the MSSharePoint). This best practice assures that: a. Student enrollment status is recorded accurately and on time. b. Withdrawal cases in which transactions are required with the USDoE are documented early so that funds are returned within the allowable prescribed period. c. As an extra bonus, communication is improved among the Registrar?s, Financial Aid and Finance Offices staff. 3. The dean of student affairs and the dean of academic affairs have provided faculty development seminars on the expectations of a faculty member to comply with federal regulations. Among the topics discussed is the importance of attendance recording and documentation. As well, faculty were required to refer to the Registrar?s and to the Dean of Admissions and Student Affairs Offices any student absent totwo consecutive significant academic events. The purpose is: a. Early detection of a student that might be at risk of academic difficulties. b. Early awareness of a student that might be changing enrollment status. 4. To date four (4) attendance surveys have taken place (3/semester). The attendance surveys provide the opportunity to capture any students at risk of changes in enrollment status. As a consequence, student enrollment status may be recorded accurately and on time and as well funds are returned to the USDoE within the allowable period. 5. Periodic letter to the faculty from the Office of the Dean of Academic Affairs to highlight the importance to promptly refer any changes in student attendance to activate retention efforts or in order to identify and record accurately and on time any changes in student enrollment status. n addition to the above-mentioned procedures the following measures will be taken: 1. Late reporting of graduation dates in NSLDS and effective dates: a. Prior to graduation all academic program directors review the degrees to be conferred and certify candidates eligible for graduation b. The Registrar?s Office changes the status to graduate in the NSLDS Report after graduation date. c. To assure that all degrees are reported on time and accurately to the NSLDS system from now on, the Registrar?s Office, within ten days after graduation date, will process the changes in the NSLDS system. After the Registrar?s Office processes the changes in the NSLDS system, it will send to all program directors the list of all the students processed as graduated in the NSLDS system and they will be asked to double verify and attest accuracy of the lists of conferred degrees and asked to provide a certification within two days that the changes processed were accurate and that they agree with their record of students officially graduated during the last graduation date. This double certification of conferred degrees within the proposed time-frame will provide a second opportunity to add or delete any missing information within the NSLDS system increasing accuracy and timelines. d. A copy of the certification will be submitted to the Office of the Dean of Academic Affairs as evidence of the compliance with the new process established.
2021-001
Finding No. 2022-002 - Special Test and Provisions ? Return of Title IV Funds ? Determination of Funds Earned Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing 84.033 - Federal Work-Study Program Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR Section 668.22(a) states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. Condition In testing compliance with the requirements for the Return of Title IV funds, we selected all nine (9) students who withdrew, dropped out or failed to attend to the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 11% of the sample selected, in which the University failed to calculate the amount of the Title IV grant (PELL) that the student had earned as of the student?s withdrawal date, as follows: ?See Schedule of Findings and Questioned Costs for chart/table? Context Of the nineteen (19) cases of students who withdrew, dropped out, or failed to attend the University, we selected all nine (9) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance (PELL) with the required criteria. The composition of the audit samples for the Pell grant program and the population from which the samples were drawn were as follows: ?See Schedule of Findings and Questioned Costs for chart/table? Cause The instance of non-compliance was mainly due to a human error in the data entry of the dates. Effect As a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, they could result in reduced availability of federal funds to other students in need of financial assistance. Questioned Cost As of the date the financial statements were available to be issued, questioned costs were not determined, since the amount of $10 had been paid by the University. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2021-006. Recommendation The University needs to improve its policies and procedures to ensure financial aid personnel is aware of all applicable regulations. Also, additional review and monitoring procedures should be implemented to ensure that the determination of the earned Title IV funds is made for all applicable students, including those who received incomplete or failing grades. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 66-76.
Show full finding ▾Hide full finding ▴Finding No. 2022-002 - Special Test and Provisions ? Return of Title IV Funds ? Determination of Funds Earned Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing 84.033 - Federal Work-Study Program Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR Section 668.22(a) states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. Condition In testing compliance with the requirements for the Return of Title IV funds, we selected all nine (9) students who withdrew, dropped out or failed to attend to the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 11% of the sample selected, in which the University failed to calculate the amount of the Title IV grant (PELL) that the student had earned as of the student?s withdrawal date, as follows: ?See Schedule of Findings and Questioned Costs for chart/table? Context Of the nineteen (19) cases of students who withdrew, dropped out, or failed to attend the University, we selected all nine (9) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance (PELL) with the required criteria. The composition of the audit samples for the Pell grant program and the population from which the samples were drawn were as follows: ?See Schedule of Findings and Questioned Costs for chart/table? Cause The instance of non-compliance was mainly due to a human error in the data entry of the dates. Effect As a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, they could result in reduced availability of federal funds to other students in need of financial assistance. Questioned Cost As of the date the financial statements were available to be issued, questioned costs were not determined, since the amount of $10 had been paid by the University. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2021-006. Recommendation The University needs to improve its policies and procedures to ensure financial aid personnel is aware of all applicable regulations. Also, additional review and monitoring procedures should be implemented to ensure that the determination of the earned Title IV funds is made for all applicable students, including those who received incomplete or failing grades. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 66-76.
An additional procedure was established since March 2023, incorporating a second checkpoint in the filling of the R2T4. After the filing, all dates required in the calculation of the withdrawal process (R2T4) will be reassured/validated by a different official at the Financial Aid Office other than the preparer. The reviewer will also initialize the R2T4 as evidence of the review and compliance with this new procedure. This system will help prevent human errors like this to occur again.
2021-006
Finding No. 2022-003 - Special Test and Provisions ? Return of Title IV Funds - Timing Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing 84.033 - Federal Work-Study Program Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR Section 668.173(b) states that returns of Title IV Funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the USDE as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Condition In testing compliance with the requirements for the Return of Title IV funds, we selected all nine (9) students who withdrew, dropped out or failed to attend to the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 11% of the sample selected, in which the University failed to return the Title IV funds (Pell) within 45 days of determining the withdrawal date, as follows: ?See Schedule of Findings and Questioned Costs for chart/table? Context Of the nineteen (19) cases of students who withdrew, dropped out, or failed to attend the University, we selected all nine (9) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance (PELL) with the required criteria.The composition of the audit samples for the Pell grant program and the population from which the samples were drawn were as follows: ?See Schedule of Findings and Questioned Costs for chart/table? Cause The student?s withdrawal was not properly processed by the Registration Department on a timely basis due to human error. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties on the University. In addition, it could result in reduced availability of federal funds to other students in need of financial assistance. Questioned Cost As of the date the financial statements were available to be issued, questioned costs were not determined, since the amount of $2,036 had been paid by the University. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2021-005. Recommendation The University needs to improve its processes, including the communication between departments, to ensure that the return of Title IV funds is made within the prescribed period of time. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 66-76.
Show full finding ▾Hide full finding ▴Finding No. 2022-003 - Special Test and Provisions ? Return of Title IV Funds - Timing Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing 84.033 - Federal Work-Study Program Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR Section 668.173(b) states that returns of Title IV Funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the USDE as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Condition In testing compliance with the requirements for the Return of Title IV funds, we selected all nine (9) students who withdrew, dropped out or failed to attend to the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 11% of the sample selected, in which the University failed to return the Title IV funds (Pell) within 45 days of determining the withdrawal date, as follows: ?See Schedule of Findings and Questioned Costs for chart/table? Context Of the nineteen (19) cases of students who withdrew, dropped out, or failed to attend the University, we selected all nine (9) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance (PELL) with the required criteria.The composition of the audit samples for the Pell grant program and the population from which the samples were drawn were as follows: ?See Schedule of Findings and Questioned Costs for chart/table? Cause The student?s withdrawal was not properly processed by the Registration Department on a timely basis due to human error. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties on the University. In addition, it could result in reduced availability of federal funds to other students in need of financial assistance. Questioned Cost As of the date the financial statements were available to be issued, questioned costs were not determined, since the amount of $2,036 had been paid by the University. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2021-005. Recommendation The University needs to improve its processes, including the communication between departments, to ensure that the return of Title IV funds is made within the prescribed period of time. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 66-76.
This error was due to the fact that the professor did not notify that the student was missing. Instead, the student was graded as if she had completed the course.In order to prevent the recurrence of this error, the university has established the following procedure: 1. The dean of student affairs and the dean of academic affairs have provided faculty development seminars on the expectations of a faculty member to comply with federal regulations. Among the topics discussed is the importance of attendance recording and documentation. As well, faculty were required to refer to the Registrar?s and to the Dean of Admissions and Student Affairs Offices any student absent to two consecutive significant academic events. The purpose is: a. Early detection of a student that might be at risk of academic difficulties. b. Early awareness of a student that might be changing enrollment status. 2. To date four (4) attendance surveys have taken place (3/semester). The attendance surveys provide the opportunity to capture any students at risk of changes in enrollment status. As a consequence, student enrollment status may be recorded accurately and on time and as well funds are returned to the USDoE within the allowable period. 3. Periodic letters to the faculty from the Office of the Dean of Academic Affairs to highlight the importance of promptly referring any changes in student attendance to activate retention efforts or in order to identify and record accurately and on time any changes in student enrollment status.
2021-005
Finding No. 2022-004 ? Compliance Requirements ? Eligibility Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing 84.033 - Federal Work-Study Program Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR Section 668.32(a)(1)(i) states that for a student to be eligible for student financial assistance programs, he or she must be a regular student enrolled or accepted for enrollment in an eligible program unless meeting an exception. Condition In testing compliance with the requirements for the Return of Title IV funds, we selected all nine (9) students who withdrew, dropped out or failed to attend the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 11% of the sample selected, in which the University disbursed Title IV funds (Direct Loan) to a non-eligible student, as follows: ?See Schedule of Findings and Questioned Costs for chart/table Context Of the nineteen (19) cases of students who withdrew, dropped out, or failed to attend the University, we selected all nine (9) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance (Direct Loans) with the required criteria. Of the nine (9) students selected for testing, only six (6) had received Direct Loans. The composition of the audit samples for the Direct Loan program and the population from which the samples were drawn were as follows: ?See Schedule of Findings and Questioned Costs for chart/table? Cause The student was incorrectly classified as enrolled by the Registrar Department due to human error. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties on the University. In addition, it could result in reduced availability of federal funds to other students in need of financial assistance. Questioned Cost As of the date the financial statements were available to be issued, questioned costs were not determined, since the amount of $14,423 had been paid by the University. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation The University needs to improve its processes over the review of student?s eligibility to ensure that only eligible students receive financial aid under federal financial assistance programs. Furthermore, controls over student enrollment should be enhanced to ensure that only qualified students are registered as enrolled in the University. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 66-76.
Show full finding ▾Hide full finding ▴Finding No. 2022-004 ? Compliance Requirements ? Eligibility Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing 84.033 - Federal Work-Study Program Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR Section 668.32(a)(1)(i) states that for a student to be eligible for student financial assistance programs, he or she must be a regular student enrolled or accepted for enrollment in an eligible program unless meeting an exception. Condition In testing compliance with the requirements for the Return of Title IV funds, we selected all nine (9) students who withdrew, dropped out or failed to attend the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 11% of the sample selected, in which the University disbursed Title IV funds (Direct Loan) to a non-eligible student, as follows: ?See Schedule of Findings and Questioned Costs for chart/table Context Of the nineteen (19) cases of students who withdrew, dropped out, or failed to attend the University, we selected all nine (9) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance (Direct Loans) with the required criteria. Of the nine (9) students selected for testing, only six (6) had received Direct Loans. The composition of the audit samples for the Direct Loan program and the population from which the samples were drawn were as follows: ?See Schedule of Findings and Questioned Costs for chart/table? Cause The student was incorrectly classified as enrolled by the Registrar Department due to human error. Effect As a result of this condition, the USDE may issue warnings and/or impose penalties on the University. In addition, it could result in reduced availability of federal funds to other students in need of financial assistance. Questioned Cost As of the date the financial statements were available to be issued, questioned costs were not determined, since the amount of $14,423 had been paid by the University. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation The University needs to improve its processes over the review of student?s eligibility to ensure that only eligible students receive financial aid under federal financial assistance programs. Furthermore, controls over student enrollment should be enhanced to ensure that only qualified students are registered as enrolled in the University. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 66-76.
The finding was due to a human error. The Registrar?s Office failed to notify the Finance Division and Financial Aid Division of the student enrollment cancellation. These kinds of human errors will be prevented with the following procedure established by the university: Beginning with academic year 2022-2023 (August-2022), the university is taking the following measures: 1. A MSSharePoint was created in collaboration among the Registrar?s, Financial Aid and Finance Offices staff to serve as an easy access documentation repository and to enhance communication. Information of changes in the enrollment status of any student is documented internally for discussion among the offices (Monthly Withdrawal Conciliation Report). 2. Monthly meetings with the Registrar?s, Financial Aid and Finance Offices staff takes place. Personnel from the Institutional Effectiveness Office, and the Offices of the Dean and the Assistant Dean of Academic Affairs also attend to facilitate the discussion. During these meetings the three offices reconcile data on student enrollment status (as documented in the MSSharePoint). This best practice assures that: a. Student enrollment status is recorded accurately and on time. b. Withdrawal cases in which transactions are required with the USDoE are documented early so that funds are returned within the allowable prescribed period. c. As an extra bonus, communication is improved among the Registrar?s, Financial Aid and Finance Offices staff. 3. The dean of student affairs and the dean of academic affairs have provided faculty development seminars on the expectations of a faculty member to comply with federal regulations. Among the topics discussed is the importance of attendance recording and documentation. As well, faculty were required to refer to the Registrar?s and to the Dean of Admissions and Student Affairs Offices any student absent to two consecutive significant academic events. The purpose is: a. Early detection of a student that might be at risk of academic difficulties. b. Early awareness of a student that might be changing enrollment status. 4. To date four (4) attendance surveys have taken place taken place (3/semester). The attendance surveys provide the opportunity to capture any students at risk of changes in enrollment status. As a consequence, student enrollment status may be recorded accurately and on time and as well funds are returned to the USDoE within the allowable period. 5. Periodic letters to the faculty from the Office of the Dean of Academic Affairs to highlight the importance pf promptly referring any changes in student attendance to activate retention efforts or in order to identify and record accurately and on time any changes in student enrollment status.
FAC accepted this audit on March 29, 2022 — management decision was due September 29, 2022.
Finding No. 2021-001 - Special Tests and Provisions ? Enrollment Reporting Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education?s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loan Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-five (25) students from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended June 30, 2021. As a result of our test, we noted that for two (2) out of twenty cases that received Student Financial Assistance funds, or 10% of the applicable sample, the University did not report to the NSLDS the students? status changes within the time prescribed by the regulations. In addition, we noted one (1) case, or 5% of the applicable sample, for which the student?s status was incorrectly reported. Context Of the 147 instances of status changed, we selected twenty-five (25) students and determined that for three (3) out of twenty (20) cases that received Student Financial Assistance funds, the University did not comply with the enrollment reporting requirements. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2020-001. Recommendation The University must ascertain that students? documentation and other information necessary to comply with the feIdentification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2020-001. Recommendation The University must ascertain that students? documentation and other information necessary to comply with the federal funds? enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.deral funds? enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
Show full finding ▾Hide full finding ▴Finding No. 2021-001 - Special Tests and Provisions ? Enrollment Reporting Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education?s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loan Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-five (25) students from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended June 30, 2021. As a result of our test, we noted that for two (2) out of twenty cases that received Student Financial Assistance funds, or 10% of the applicable sample, the University did not report to the NSLDS the students? status changes within the time prescribed by the regulations. In addition, we noted one (1) case, or 5% of the applicable sample, for which the student?s status was incorrectly reported. Context Of the 147 instances of status changed, we selected twenty-five (25) students and determined that for three (3) out of twenty (20) cases that received Student Financial Assistance funds, the University did not comply with the enrollment reporting requirements. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement. Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2020-001. Recommendation The University must ascertain that students? documentation and other information necessary to comply with the feIdentification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2020-001. Recommendation The University must ascertain that students? documentation and other information necessary to comply with the federal funds? enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.deral funds? enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
As part of the required updates to the National Student Loan Data System (NSLDS), the Registrar submits to the Assistant Registrar the detail of students that changed enrollment status during the period. Due to human error, in the sample selected two changes were informed outside the prescribed period. 1. To monitor that changes in student enrollment status are registered within the required period, UCC will monthly reconcile the information submitted by the Registrar to the Assistant Registrar. This reconciliation report will be submitted to the Dean of Academic Affairs for review and evidence of compliance with the established procedure. 2. The student attendance policy was revised to include at least three attendance verification surveys per semester. The dates for faculty and programs compliance with attendance verification surveys were added to the institutional calendar for academic year 2022-2023. Close oversight will be provided in order to assure that any changes in student enrollment status are captured early and timely recorded to the NSLDS system. Name of Contact: Ms. Nereida Diaz, PhD, Dean of Academics Affairs.
2020-001
Finding No. 2021-002 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation - Reporting Federal Program Students Financial Assistance Programs Cluster - Assistance Listing 84.268 - Federal Direct Student Loans Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria A school must submit Pell Grant, TEACH Grant, and Direct Loan disbursement records no later than 15 days after making a disbursement or becoming aware of the need to adjust a student?s disbursement. Condition In testing compliance with the requirements for Borrower Data Transmission and Reconciliation under the Direct Loans program, we selected sixty (60) participants who received Direct Loans and noted five (5) instances, or 8% of the sample selected, for which the University failed to properly submit the disbursement records to the Common Origination and Disbursement (COD) center within 15 days of the disbursement date. Context Of the three hundred and seventy (370) students that received Direct Loans, we selected sixty (60) students and noted five (5) instances of non-compliance with the required criteria. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement during the second semester of the fiscal year. Effect Failure to ensure the accuracy of the information provided and to submit the required records in a timely manner may be considered by the grantor as a noncompliance and could lead to administrative sanctions by the grantor. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2020-002. Recommendation Management must establish the necessary administrative and monitoring control procedures to ensure the accuracy and completeness of the information provided to the COD and that such information is submitted to the COD on a timely basis. The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
Show full finding ▾Hide full finding ▴Finding No. 2021-002 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation - Reporting Federal Program Students Financial Assistance Programs Cluster - Assistance Listing 84.268 - Federal Direct Student Loans Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria A school must submit Pell Grant, TEACH Grant, and Direct Loan disbursement records no later than 15 days after making a disbursement or becoming aware of the need to adjust a student?s disbursement. Condition In testing compliance with the requirements for Borrower Data Transmission and Reconciliation under the Direct Loans program, we selected sixty (60) participants who received Direct Loans and noted five (5) instances, or 8% of the sample selected, for which the University failed to properly submit the disbursement records to the Common Origination and Disbursement (COD) center within 15 days of the disbursement date. Context Of the three hundred and seventy (370) students that received Direct Loans, we selected sixty (60) students and noted five (5) instances of non-compliance with the required criteria. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement during the second semester of the fiscal year. Effect Failure to ensure the accuracy of the information provided and to submit the required records in a timely manner may be considered by the grantor as a noncompliance and could lead to administrative sanctions by the grantor. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2020-002. Recommendation Management must establish the necessary administrative and monitoring control procedures to ensure the accuracy and completeness of the information provided to the COD and that such information is submitted to the COD on a timely basis. The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
Cases of non-compliance arise from a change in the disbursement date made during the first payroll of the second semester. The original disbursement day was changed by agreement between the Financial Aid Office and the Finance Office after the financial aid office reported the disbursement date in COD. The Financial Aid office reported the change in COD after the required period. To ensure that the disbursement date is the same in the finance office and in the COD system; In 2021, we implemented a process in which the specific date of disbursement was coordinated between the Financial Aid Office and the finance office before recording the information in COD, however, a human error was identified in the Audit. As a new procedure to prevent the instance of noncompliance identified during the audit, we established an additional reconciliation of the actual date of disbursement between the Economic Assistance Office and the Finance Office. The Financial Aid Office will correct, if necessary, any change in the disbursement date within 15 days. As part of the current procedures, we are reviewing that the 2021-2022 disbursement date in COD is the same disbursement date in the finance office. The reconciliation will be made in the five (5) days period after the actual disbursement date. A written confirmation of each reconciliation will be submitted to the Chief Financial Officer for review purposes and evidence of compliance with the new procedure. Name of Contact: Mr. Omar Perez, PhD, Dean of Admission and Student Affairs and Mr. Ariel Davila, CPA, VP & CFO.
2020-002
Finding No. 2021-003 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation ?Reporting Federal Program Students Financial Assistance Programs Cluster - Assistance Listing 84.063 - Federal Pell Grant Programs Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria A school must submit Pell Grant, TEACH Grant, and Direct Loan disbursement records no later than 15 days after making a disbursement or becoming aware of the need to adjust a student?s disbursement. Condition In testing compliance with the requirements for reporting under the Pell Grant program, we selected eleven (11) participants who received the Pell Grant and noted ten (10) instances, or 91% of the sample selected, for which the University failed to properly submit the disbursement records to the COD within 15 days of the disbursement date. Context Of the one hundred and two (102) students that received the Pell Grant, we selected eleven (11) students and noted ten (10) instances of non-compliance with the required criteria. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement during the fiscal year. Effect Failure to ensure the accuracy of the information provided and to submit the required records in a timely manner may be considered by the grantor as a noncompliance and could lead to administrative sanctions by the grantor. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2020-003. Recommendation Management must establish the necessary administrative and monitoring control procedures to ensure the accuracy and completeness of the information provided to the COD and that such information is submitted to the COD on a timely basis. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
Show full finding ▾Hide full finding ▴Finding No. 2021-003 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation ?Reporting Federal Program Students Financial Assistance Programs Cluster - Assistance Listing 84.063 - Federal Pell Grant Programs Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria A school must submit Pell Grant, TEACH Grant, and Direct Loan disbursement records no later than 15 days after making a disbursement or becoming aware of the need to adjust a student?s disbursement. Condition In testing compliance with the requirements for reporting under the Pell Grant program, we selected eleven (11) participants who received the Pell Grant and noted ten (10) instances, or 91% of the sample selected, for which the University failed to properly submit the disbursement records to the COD within 15 days of the disbursement date. Context Of the one hundred and two (102) students that received the Pell Grant, we selected eleven (11) students and noted ten (10) instances of non-compliance with the required criteria. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement during the fiscal year. Effect Failure to ensure the accuracy of the information provided and to submit the required records in a timely manner may be considered by the grantor as a noncompliance and could lead to administrative sanctions by the grantor. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2020-003. Recommendation Management must establish the necessary administrative and monitoring control procedures to ensure the accuracy and completeness of the information provided to the COD and that such information is submitted to the COD on a timely basis. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
Difference between disbursement date in COD and in the Finance office records were corrected after the 15 days? timeframe establish by the Department of Education. The Office of Financial Aid recorded as disbursement date in COD the day in which it delivers the Pell payroll to the finance Department. Since the Department of Education makes the drawdown of funds 2 or 3 days after the finance office request the funds, a difference in dates arise between COD and the Finance Office. To preclude the discrepancy the Office of Financial Aid is currently providing the Pell payroll to the Finance Office 7 days ahead of the disbursement date recorded in COD. With the new procedure the Finance Office will have enough time to request the funds and receive the drawdown by the day recorded in COD. Name of Contact: Mr. Omar Perez, PhD, Dean of Admission and Student Affairs and Mr. Ariel Davila, CPA, VP & CFO.
2020-003
Finding No. 2021-004 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation Federal Program Students Financial Assistance Programs Cluster - Assistance Listing 84.268 - Federal Direct Student Loans Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Each month, the COD provides institutions with a School Account Statement (SAS) data file, which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the institution?s financial records. Condition In order to test this compliance requirement, we requested the monthly reconciliations of the SAS data files with the University?s financial records, but none was available. As per discussions with management, an informal reconciliation is performed on a monthly basis, however, such reconciliations are not retained. Context No monthly reconciliations were available for out test. Cause The University did not retain the monthly reconciliations because of lack of knowledge by the responsible employee. Effect In addition to potential sanctions that may be imposed by the grantor, the lack of a formal reconciliation process may prevent the University from identifying differences between its financial records and the information provided by the COD. Questioned Cost None. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation Management must establish the necessary administrative and monitoring control procedures to ensure that SAS data files are reconciled on a monthly basis to ascertain the accuracy and completeness of the information provided to the COD. In addition, such reconciliations should be formally documented and retained by the University. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
Show full finding ▾Hide full finding ▴Finding No. 2021-004 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation Federal Program Students Financial Assistance Programs Cluster - Assistance Listing 84.268 - Federal Direct Student Loans Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria Each month, the COD provides institutions with a School Account Statement (SAS) data file, which consists of a Cash Summary, Cash Detail, and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the institution?s financial records. Condition In order to test this compliance requirement, we requested the monthly reconciliations of the SAS data files with the University?s financial records, but none was available. As per discussions with management, an informal reconciliation is performed on a monthly basis, however, such reconciliations are not retained. Context No monthly reconciliations were available for out test. Cause The University did not retain the monthly reconciliations because of lack of knowledge by the responsible employee. Effect In addition to potential sanctions that may be imposed by the grantor, the lack of a formal reconciliation process may prevent the University from identifying differences between its financial records and the information provided by the COD. Questioned Cost None. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation Management must establish the necessary administrative and monitoring control procedures to ensure that SAS data files are reconciled on a monthly basis to ascertain the accuracy and completeness of the information provided to the COD. In addition, such reconciliations should be formally documented and retained by the University. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
The Financial Aid office makes periodic reconciliations with the Finance office, but these were done with printed lists and were not saved after being reconciled, we only kept one reconciled SAS file. Since August 2021 the financial aid office has being using a monthly SAS file for reconciliation with the payroll file from the Finance office and the payroll from the financial aid office. A copy of these reconciliations is now available for audit purposes. Name of Contact: Name of Contact: Mr. Omar Perez, PhD, Dean of Admission and Student Affairs.
Finding No. 2021-005 - Special Test and Provisions ? Return of Title IV Funds - Timing Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing 84.033 - Federal Work-Study Program Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR Section 668.173(b) states that returns of Title IV Funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the USDE as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Condition In testing compliance with the requirements for the Return of Title IV funds, we selected a sample of six (6) students who withdrew, dropped out or failed to attend to the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 17% of the sample selected, in which the University failed to return the Title IV funds (Pell) within 45 days of determining the withdrawal date, as follows: Context Of the thirty-two (32) cases of students who withdrew, dropped out, or failed to attend to the University, we selected six (6) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance (Pell) with the required criteria. Following is a description of each sample and the population from which the samples were drawn for students that received Pell funds during the year ended June 30, 2021: Cause The withdrawal was processed by the Financial Aid Office, however, it was not reported to the Fiscal Resources Office on a timely basis due to human error. Effect As a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, they could result in reduced availability of federal funds to other students in need of financial assistance. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2020-004. Recommendation The University needs to improve its processes, including the communication between departments, to ensure that the return of Title IV funds is made within the prescribed period of time. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
Show full finding ▾Hide full finding ▴Finding No. 2021-005 - Special Test and Provisions ? Return of Title IV Funds - Timing Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing 84.033 - Federal Work-Study Program Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR Section 668.173(b) states that returns of Title IV Funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the USDE as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew. Condition In testing compliance with the requirements for the Return of Title IV funds, we selected a sample of six (6) students who withdrew, dropped out or failed to attend to the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 17% of the sample selected, in which the University failed to return the Title IV funds (Pell) within 45 days of determining the withdrawal date, as follows: Context Of the thirty-two (32) cases of students who withdrew, dropped out, or failed to attend to the University, we selected six (6) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance (Pell) with the required criteria. Following is a description of each sample and the population from which the samples were drawn for students that received Pell funds during the year ended June 30, 2021: Cause The withdrawal was processed by the Financial Aid Office, however, it was not reported to the Fiscal Resources Office on a timely basis due to human error. Effect As a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, they could result in reduced availability of federal funds to other students in need of financial assistance. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2020-004. Recommendation The University needs to improve its processes, including the communication between departments, to ensure that the return of Title IV funds is made within the prescribed period of time. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
The Registrar office processed the authorized withdrawal application form when it was requested by the student. However, the withdrawal was made outside of the timeframe period established by the DoE. To ascertain that R2T4s are prepared within the regulatory timeframe, UCC will implement a new procedure in which the Registrar office will submit (to the office of Financial Aid and the Finances division) on a monthly basis a summary of all withdrawals in progress or processed. They will meet and reconcile all withdrawal information. Also, they will assure that the corresponding R2T4s are processed within the timeframe established by the DoE. Copy of this reconciliation report will be submitted to the Dean of Academic Affairs and the Dean of Student Affairs for review and as evidence of compliance. Name of Contact: Mr. Omar Perez, PhD, Dean of Admission and Student Affairs and Ms. Nereida Diaz, PhD, Dean of Academics Affairs.
2020-004
Finding No. 2021-006 - Special Test and Provisions ? Return of Title IV Funds ? Determination of Funds Earned Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing 84.033 - Federal Work-Study Program Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR Section 668.22(a) states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. Criteria 34 CFR Section 668.22(a) states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date. Condition In testing compliance with the requirements for the Return of Title IV funds, we selected six (6) students who withdrew, dropped out or failed to attend to the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 17% of the sample selected, in which the University failed to calculate the amount of the Title IV grant (PELL) that the student had earned as of the student?s withdrawal date, as follows: Context Of the thirty-two (32) cases of students who withdrew, dropped out, or failed to attend to the University, we examined six (6) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance (PELL) with the required criteria. Following is a description of each sample and the population from which the samples were drawn for students that received Pell funds during the year ended June 30, 2021: Cause The instance of non-compliance was mainly due to a lack of proper oversight over this requirement. Effect As a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, they could result in reduced availability of federal funds to other students in need of financial assistance. Questioned Cost None. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation The University needs to improve its policies and procedures to ensure financial aid personnel is aware of all applicable regulations. In addition, additional review and monitoring procedures should be implemented to ensure that the determination of the earned Title IV funds is made for all applicable students, including those who received incomplete or failing grades. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
Show full finding ▾Hide full finding ▴Finding No. 2021-006 - Special Test and Provisions ? Return of Title IV Funds ? Determination of Funds Earned Federal Program Students Financial Assistance Programs Cluster: Assistance Listing 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) Assistance Listing 84.033 - Federal Work-Study Program Assistance Listing 84.063 - Federal Pell Grant Program Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR Section 668.22(a) states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the student?s withdrawal date. Criteria 34 CFR Section 668.22(a) states that when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must determine the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date. Condition In testing compliance with the requirements for the Return of Title IV funds, we selected six (6) students who withdrew, dropped out or failed to attend to the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 17% of the sample selected, in which the University failed to calculate the amount of the Title IV grant (PELL) that the student had earned as of the student?s withdrawal date, as follows: Context Of the thirty-two (32) cases of students who withdrew, dropped out, or failed to attend to the University, we examined six (6) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance (PELL) with the required criteria. Following is a description of each sample and the population from which the samples were drawn for students that received Pell funds during the year ended June 30, 2021: Cause The instance of non-compliance was mainly due to a lack of proper oversight over this requirement. Effect As a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, they could result in reduced availability of federal funds to other students in need of financial assistance. Questioned Cost None. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation The University needs to improve its policies and procedures to ensure financial aid personnel is aware of all applicable regulations. In addition, additional review and monitoring procedures should be implemented to ensure that the determination of the earned Title IV funds is made for all applicable students, including those who received incomplete or failing grades. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
The Registrar office submitted to the office of Financial Assistance the application for authorized withdrawal form after a student withdrew for the corresponding R2T4. To ascertain that R2T4s are prepared in every withdrawal, UCC will implement a new procedure in which the Registrar office will submit on a monthly basis (to the office of Financial Aid and the Finances division) a summary of all withdrawals in progress or processed. They will meet and reconcile all withdrawal information. Also, they will assure that the corresponding R2T4s are processed within the timeframe established by the DoE. Copy of this reconciliation report will be submitted to the Dean of Academic Affairs and the Dean of Student Affairs for review and as evidence of compliance. Name of Contact: Name of Contact: Mr. Omar Perez, PhD, Dean of Admission and Student Affairs.
Finding No. 2021-007 - Special Test and Provisions ? Disbursement to or on Behalf of Students under the Federal Direct Student Loan Program ? Credit Balances Federal Program Students Financial Assistance Programs Cluster - Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR Section 668.164 (h) states that a Title IV credit balance occurs whenever the amount of title IV program funds credited to a student?s ledger for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. The credit balance must be paid directly to the student or parent as soon as possible, but no later than ? fourteen days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or ? fourteen days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition In testing compliance with the requirements for disbursements under the Direct Loans program, we selected sixty (60) participants who received direct loans. During our evaluation of compliance with these requirements, we noted one (1) instance, or 2% of the sample selected, in which the University incorrectly calculated the credit balance. In addition, the resulting pending credit balance due to the student was paid after the required fourteen days, as follows: Context Of the three hundred and seventy (370) students that received direct loans, we selected sixty (60) students and noted one (1) instance of non-compliance with the required criteria. Following is a description of each sample and the population from which the samples were drawn for students that received Direct Loans funds during the year ended June 30, 2021: Cause This instance of non-compliance was mainly due to human error, since the University personnel erroneously processed payroll roster based on information pertaining to a different student with the same name, which resulted in the credit balance to the incorrect student with the same name. Effect Failure to make the correct credit balance payment within the prescribed time limit may be considered by the grantor as a noncompliance and could lead to administrative sanctions by the grantor. Questioned Cost None, since the credit balance due to the student of $3,527 was paid to the student on July 9, 2021 before the submission of the June 30, 2021 FISAP in September 2021. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation The University needs to implement additional procedures to ensure that student?s names in payroll rosters are processed correctly such that refunds are properly paid to the students within the time limit established in the regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
Show full finding ▾Hide full finding ▴Finding No. 2021-007 - Special Test and Provisions ? Disbursement to or on Behalf of Students under the Federal Direct Student Loan Program ? Credit Balances Federal Program Students Financial Assistance Programs Cluster - Assistance Listing 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR Section 668.164 (h) states that a Title IV credit balance occurs whenever the amount of title IV program funds credited to a student?s ledger for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. The credit balance must be paid directly to the student or parent as soon as possible, but no later than ? fourteen days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or ? fourteen days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition In testing compliance with the requirements for disbursements under the Direct Loans program, we selected sixty (60) participants who received direct loans. During our evaluation of compliance with these requirements, we noted one (1) instance, or 2% of the sample selected, in which the University incorrectly calculated the credit balance. In addition, the resulting pending credit balance due to the student was paid after the required fourteen days, as follows: Context Of the three hundred and seventy (370) students that received direct loans, we selected sixty (60) students and noted one (1) instance of non-compliance with the required criteria. Following is a description of each sample and the population from which the samples were drawn for students that received Direct Loans funds during the year ended June 30, 2021: Cause This instance of non-compliance was mainly due to human error, since the University personnel erroneously processed payroll roster based on information pertaining to a different student with the same name, which resulted in the credit balance to the incorrect student with the same name. Effect Failure to make the correct credit balance payment within the prescribed time limit may be considered by the grantor as a noncompliance and could lead to administrative sanctions by the grantor. Questioned Cost None, since the credit balance due to the student of $3,527 was paid to the student on July 9, 2021 before the submission of the June 30, 2021 FISAP in September 2021. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation The University needs to implement additional procedures to ensure that student?s names in payroll rosters are processed correctly such that refunds are properly paid to the students within the time limit established in the regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-73.
When searching for the student's information, it emerged that there were two students with the same first and last name. UCC were only validating the information based on student name. To ensure correct identification of students? deposits validation of student identity is now using the institutional ID number and the student name. Name of Contact: Name of Contact: Mr. Omar Perez, PhD, Dean of Admission and Student Affairs.
FAC accepted this audit on June 17, 2021 — management decision was due December 17, 2021.
Finding No. 2020-001 - Special Tests and Provisions ? Enrollment Reporting Federal ProgramStudents Financial Assistance Programs Cluster: CFDA 84.063 - Federal Pell Grant ProgramCFDA 84.268 - Federal Direct Student Loans Program Name of Federal AgencyU.S. Department of Education (USDE)Pass-through EntityN/ACriteriaThe National Student Loan Data System (NSLDS) is the U.S. Department of Education?s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients.The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program.A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loan Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence ConditionIn testing compliance and internal control over compliance with enrollment reporting, we selected twenty-five (25) participants of the Federal Pell Grant Program (Pell Grant) and/or the Federal Direct Student Loans Program (Direct Loans) from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended in June 30, 2020.As a result of our test, we noted that four (4) out of nineteen cases that received Student Financial Assistance funds, or 21% of the applicable sample, the University did not report to the NSLDS the students? status changes within the time prescribed by the regulations.ContextOf the 150 cases of status changed, we selected twenty-five (25) students and determined that four (4) of nineteen (19) cases that received Student Financial Assistance funds did not comply with the enrollment reporting requirements.CauseLate submissions were due to a misinterpretation in the definition of the effective date that in all instances was interpreted and recorded as the enrollment date.EffectAs a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis.Questioned CostNone.Identification of a repeat findingThis is a repeat finding from the immediate previous audit. Finding 2019-001. RecommendationThe University must ascertain that students? documentation and other information necessary to comply with the federal funds? enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations.Views of responsible officials and corrective action planThe University management agrees with this finding. Please refer to the corrective action plan on pages 68-75.
Show full finding ▾Hide full finding ▴Finding No. 2020-001 - Special Tests and Provisions ? Enrollment Reporting Federal ProgramStudents Financial Assistance Programs Cluster: CFDA 84.063 - Federal Pell Grant ProgramCFDA 84.268 - Federal Direct Student Loans Program Name of Federal AgencyU.S. Department of Education (USDE)Pass-through EntityN/ACriteriaThe National Student Loan Data System (NSLDS) is the U.S. Department of Education?s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients.The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program.A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loan Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence ConditionIn testing compliance and internal control over compliance with enrollment reporting, we selected twenty-five (25) participants of the Federal Pell Grant Program (Pell Grant) and/or the Federal Direct Student Loans Program (Direct Loans) from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended in June 30, 2020.As a result of our test, we noted that four (4) out of nineteen cases that received Student Financial Assistance funds, or 21% of the applicable sample, the University did not report to the NSLDS the students? status changes within the time prescribed by the regulations.ContextOf the 150 cases of status changed, we selected twenty-five (25) students and determined that four (4) of nineteen (19) cases that received Student Financial Assistance funds did not comply with the enrollment reporting requirements.CauseLate submissions were due to a misinterpretation in the definition of the effective date that in all instances was interpreted and recorded as the enrollment date.EffectAs a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis.Questioned CostNone.Identification of a repeat findingThis is a repeat finding from the immediate previous audit. Finding 2019-001. RecommendationThe University must ascertain that students? documentation and other information necessary to comply with the federal funds? enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Furthermore, additional procedures need to be implemented to ensure that enrollment reporting submissions are completed within the timeframe required by such regulations.Views of responsible officials and corrective action planThe University management agrees with this finding. Please refer to the corrective action plan on pages 68-75.
Finding No. 2020-001-Enrollment ReportingAs part of the Universidad Central del Caribe?s (UCC) efforts to achieve its maximum level of compliance with the laws and regulations of the United States Department of Education(USDE) Federal Student Assistance Programs, the university started reengineering processes in the tasks and duties related to enrollment and financial aid to ensure compliance based on accountability. With the addition of these changes, the UCC is aiming to achieve the integra-tion needed among student support services, academic affairs, and administrative affairs to re-duce clerical errors in the reporting to the USDE.Previously, the Registrar?s Office, the Financial Aid Office, and the Division of Finance exe-cuted the enrollment related tasks/processes separately, by department. During 2020-2021, the enrollment process was reconfigured and the related services and processes were re-vamped in order to integrate them and ascertain that the required check and balance steps were added to accomplish additional validations and reconciliations in order to prevent and reduce the occurrence of the clerical errors noted during the 2019-2020 audit.Significant improvements in student enrollment reporting have been achieved. Actions un-dertaken are rendering the anticipated results. However, the external audit reflected four in-stances in which the change in enrollment status date was reported late (due to clerical errors or delays in the reporting to/of the Registrar?s Office). In order to prevent this situation from repeating, the following actions will be taken and reinforced:Administration: 1. The Office of the Dean of Student Affairs will continue educating all members of the academic community on their responsibilities and the procedures in place to promptly report any changes in enrollment status to:a. The Registrar?s Office: to accurately and timely report to NSLDS (as re-quired). b. The assistant dean of admissions and student affairs: to offer all academic and personal support available to the student (as necessary).2. Development of a Microsoft SharePoint to record and track changes in the enroll-ment status:a. The Office of the Registrar will develop a SharePoint to record and track changes in the enrollment status as reported by faculty, students, and staff. A three-level checkpoint will be established to assure timely reporting to the NSLDS:i. The registrar will record the first report of a student enrollment sta-tus.ii. The assistant registrar will weekly check, record, and report to NSLDS any changes as confirmed.iii. The administrative assistant will perform the third round checks every two weeks, sending reminders to the registrar and the assis-tant registrar on any pending status change reports. Faculty and Academic Program Administrators: 1. Faculty will be required by the dean of academic affairs (with the follow up from the Registrar?s Office) to report to the program directors and faculty deans any student that misses any academic activity over two consecutive days. Faculty deans will be responsible to promptly report those cases to:a. The Registrar?s Office: to accurately and timely report to NSLDS (as neces-sary).b. The assistant dean of admissions and student affairs: to offer all academic and personal support available to the student (as necessary). Prepared and submitted: Nereida D. Diaz Rodriguez, PhD Dean of Academic Affairs
2019-001
Finding No. 2020-002 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation - ReportingFederal ProgramStudents Financial Assistance Programs Cluster -CFDA 84.268 - Federal Direct Student LoansName of Federal AgencyU.S. Department of EducationPass-through EntityN/ACriteriaA school must submit Pell Grant, TEACH Grant, and Direct Loan disbursement records no later than 15 days after making a disbursement or becoming aware of the need to adjust a student's disbursement.ConditionIn testing compliance with the requirements for Borrower Data Transmission and Reconciliation under the Direct Loans program, we selected sixty (60) participants who received Direct Loans.During our evaluation of compliance with these requirements, we noted six (6) instances, or 10% of the sample selected, in which the University failed to properly submit the disbursement records to the Common Origination and Disbursement (COD) center within 15 days of the disbursement date. In addition, for these students, the disbursement date per COD submissions did not match the actual disbursement dates per the University?s financial records.ContextOf the three hundred and forty-six (346) students that received Direct Loans, we selected sixty (60) students and noted six (6) instances of non-compliance with the required criteria.CauseInstances of non-compliance were mainly due to a lack of proper oversight over this requirement during the first semester of the fiscal year.EffectFailure to ensure the accuracy of the information provided and to submit the required records in a timely manner may be considered by the grantor as a noncompliance with the required criteria and could lead to administrative sanctions by the grantor.Questioned CostNone.Identification of a repeat findingThis is a repeat finding from the immediate previous audit. Finding 2019-003. RecommendationManagement must establish the necessary administrative and monitoring control procedures to ensure the accuracy and completeness of the information provided to the COD and that such information is submitted to the COD on a timely basis.Views of responsible officials and corrective action planThe University management agrees with this finding. Please refer to the corrective action plan on pages 68-75.
Show full finding ▾Hide full finding ▴Finding No. 2020-002 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation - ReportingFederal ProgramStudents Financial Assistance Programs Cluster -CFDA 84.268 - Federal Direct Student LoansName of Federal AgencyU.S. Department of EducationPass-through EntityN/ACriteriaA school must submit Pell Grant, TEACH Grant, and Direct Loan disbursement records no later than 15 days after making a disbursement or becoming aware of the need to adjust a student's disbursement.ConditionIn testing compliance with the requirements for Borrower Data Transmission and Reconciliation under the Direct Loans program, we selected sixty (60) participants who received Direct Loans.During our evaluation of compliance with these requirements, we noted six (6) instances, or 10% of the sample selected, in which the University failed to properly submit the disbursement records to the Common Origination and Disbursement (COD) center within 15 days of the disbursement date. In addition, for these students, the disbursement date per COD submissions did not match the actual disbursement dates per the University?s financial records.ContextOf the three hundred and forty-six (346) students that received Direct Loans, we selected sixty (60) students and noted six (6) instances of non-compliance with the required criteria.CauseInstances of non-compliance were mainly due to a lack of proper oversight over this requirement during the first semester of the fiscal year.EffectFailure to ensure the accuracy of the information provided and to submit the required records in a timely manner may be considered by the grantor as a noncompliance with the required criteria and could lead to administrative sanctions by the grantor.Questioned CostNone.Identification of a repeat findingThis is a repeat finding from the immediate previous audit. Finding 2019-003. RecommendationManagement must establish the necessary administrative and monitoring control procedures to ensure the accuracy and completeness of the information provided to the COD and that such information is submitted to the COD on a timely basis.Views of responsible officials and corrective action planThe University management agrees with this finding. Please refer to the corrective action plan on pages 68-75.
2020-02Finding Type: ReportingFederal Agency: Federal Program Title: CFDA No.: 84.268 ConditionIn testing compliance with the requirements for Bonower Data Transmission and Reconciliation under the Direct Loans program, we selected sixty (60) participants who received Direct LoansDuring our evaluation of compliance with these requirements, we noted six (6) instances, or I 0% of the sample selected, in which the University failed to properly submit the disbursement records to the Common Origination and Disbursement (COD) center within 15 days of the disbursement date. In addition, for these students, the disbursement date per COD submissions did not match the actual disbursement dates per the University's financial records.ContextOf the three hundred and forty-six (346) students that received Direct Loans, we selected sixty (60) students and noted six (6) instances of non-compliance with the required criteria. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement during the frrst semester of the fiscal year. Effect Failure to ensure the accuracy of the information provided and to submit the required records in a timely manner may be considered by the grantor as a noncompliance with the required criteria and could lead to administrative sanctions by the grantor.Questioned CostsNoneRecommendationRecommendation Management must establish the necessary administrative and monitoring control procedures to ensure the accuracy and completeness of the information provided to the COD and that such infonnation is submitted to the COD on a timely basis.Action PlanThe UCC immediately initiated changes in the procedures reinforcing all related documentation process in order to prevent this situation to happen again. We have implemented the total verification of the disbursements established in each payroll with those reflected in the System of the Department of Education or EDExpress. In addition, a file with the students worked on each payroll and the amounts granted will be monitored. For the purpose of reconciliation and internal audit this process will be worked in coordination with the Finance office. Dr. Omar Perez, Dean of Administration and Student Affairs
2019-003
Finding No. 2020-003 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation ?ReportingFederal ProgramStudents Financial Assistance Programs Cluster -CFDA 84.063 - Federal Pell Grant ProgramsName of Federal AgencyU.S. Department of EducationPass-through EntityN/ACriteriaA school must submit Pell Grant, TEACH Grant, and Direct Loan disbursement records no later than 15 days after making a disbursement or becoming aware of the need to adjust a student?s disbursement.ConditionIn testing compliance with the requirements for reporting under the Pell Grant Program, we selected twelve (12) participants who received the Pell Grant.During our evaluation of compliance with these requirements, we noted six (6) instances, or 50% of the sample selected, in which the University failed to properly submit the disbursement records to the COD within 15 days of the disbursement date. In addition, for two (2) of these students, or 17% of the sample selected, the disbursement date per COD did not match the actual disbursement dates per the University?s financial records.ContextOf the hundred and ten (110) students that received the Pell Grant, we selected twelve (12) students and noted six (6) and two (2) instances of non-compliance, respectively, with the required criteria.CauseInstances of non-compliance were mainly due to a lack of proper oversight over this requirement during the first semester of the fiscal year.EffectFailure to ensure the accuracy of the information provided and to submit the required records in a timely manner may be considered by the grantor as a noncompliance with the required criteria and could lead to administrative sanctions by the grantor.Questioned CostNone.Identification of a repeat findingThis is a repeat finding from the immediate previous audit. Finding 2019-004.RecommendationManagement must establish the necessary administrative and monitoring control procedures to ensure the accuracy and completeness of the information provided to the COD and that such information is submitted to the COD on a timely basis. Views of responsible officials and corrective action planThe University management agrees with this finding. Please refer to the corrective action plan on pages 68-75.
Show full finding ▾Hide full finding ▴Finding No. 2020-003 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation ?ReportingFederal ProgramStudents Financial Assistance Programs Cluster -CFDA 84.063 - Federal Pell Grant ProgramsName of Federal AgencyU.S. Department of EducationPass-through EntityN/ACriteriaA school must submit Pell Grant, TEACH Grant, and Direct Loan disbursement records no later than 15 days after making a disbursement or becoming aware of the need to adjust a student?s disbursement.ConditionIn testing compliance with the requirements for reporting under the Pell Grant Program, we selected twelve (12) participants who received the Pell Grant.During our evaluation of compliance with these requirements, we noted six (6) instances, or 50% of the sample selected, in which the University failed to properly submit the disbursement records to the COD within 15 days of the disbursement date. In addition, for two (2) of these students, or 17% of the sample selected, the disbursement date per COD did not match the actual disbursement dates per the University?s financial records.ContextOf the hundred and ten (110) students that received the Pell Grant, we selected twelve (12) students and noted six (6) and two (2) instances of non-compliance, respectively, with the required criteria.CauseInstances of non-compliance were mainly due to a lack of proper oversight over this requirement during the first semester of the fiscal year.EffectFailure to ensure the accuracy of the information provided and to submit the required records in a timely manner may be considered by the grantor as a noncompliance with the required criteria and could lead to administrative sanctions by the grantor.Questioned CostNone.Identification of a repeat findingThis is a repeat finding from the immediate previous audit. Finding 2019-004.RecommendationManagement must establish the necessary administrative and monitoring control procedures to ensure the accuracy and completeness of the information provided to the COD and that such information is submitted to the COD on a timely basis. Views of responsible officials and corrective action planThe University management agrees with this finding. Please refer to the corrective action plan on pages 68-75.
ConditionIn testing compliance with the requirements for reporting under the Pell Grant program, we selected twelve(12) participants who received the Pell Grant. During our evaluation of compliance with these requirements, we noted six (6) instances, or 50% of the sample selected, in which the University failed to properly submit the disbursement records to the COD within 15 days of the disbursement date. In addition, for two (2) of these students, or 17% of the sample selected, the disbursement date per COD did not match the actual disbursement dates per the University's financial records.Of the hundred and ten (110) students that received the Pell Grant, we selected twelve (12) students and noted six (6) and two (2) instances of non-compliance, respectively, with the required criteria.Questioned CostsNoneReconnnendationRecommendation Management must establish the necessary administrative and monitoring control procedures to ensure the accuracy and completeness of the information provided to the COD and that such information is submitted to the COD on a timely basis.Action PlanThe UCC immediately initiated changes in the procedures reinforcing all related documentation process in order to prevent this situation to happen again. We have implemented the total verification of the disbursements established in each payroll with those reflected in the System of the Department of Education or EDExpress. In addition, a file with the students worked on each payroll and the amounts granted will be monitored. For the purpose of reconciliation and internal audit this process will be worked in coordination with the Finance office. Dr. Omar Perez, Dean of Administration and Student Affairs
2019-004
Finding No. 2020-004 - Special Test and Provisions ? Return of Title IV Funds - TimingFederal ProgramStudents Financial Assistance Programs Cluster: CFDA 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA 84.033 - Federal Work-Study ProgramCFDA 84.063 - Federal Pell Grant ProgramCFDA 84.268 - Federal Direct Student Loans Program Name of Federal AgencyU.S. Department of EducationPass-through EntityN/ACriteria34 CFR Section 668.173(b) states that returns of Title IV Funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the USDE as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew.ConditionIn testing compliance with the requirements for the Return of Title IV funds, we selected the two (2) students who withdrew, dropped out or failed to attend to the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 50% of the sample selected, in which the University failed to return the Title IV funds (Direct Loans) amounting to $9,158.96 within 45 days of determining the withdrawal date.ContextOf the fifty-four (54) cases of students who withdrew, dropped out, or failed to attend to the University, we examined the two (2) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance with the required criteria.Following is a description of each sample and the population from which the samples were drawn for students that received Direct Loans funds during the year ended June 30, 2020: "see schedule of findings and questioned costs chart/table" Cause Withdrawals were processed by the Financial Aid Office, however, they were not properly reported to the Fiscal Resources Office on a timely basis due to human error. EffectAs a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, they could result in reduced availability of federal funds to other students in need of financial assistance.Questioned CostNone.Identification of a repeat findingThis is not a repeat finding from the immediate previous audit.RecommendationThe University needs to improve its processes, including the communication between departments, to ensure that the return of Title IV funds is made within the prescribed period of time.Views of responsible officials and corrective action planThe University management agrees with this finding. Please refer to the corrective action plan on pages 68-75.
Show full finding ▾Hide full finding ▴Finding No. 2020-004 - Special Test and Provisions ? Return of Title IV Funds - TimingFederal ProgramStudents Financial Assistance Programs Cluster: CFDA 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA 84.033 - Federal Work-Study ProgramCFDA 84.063 - Federal Pell Grant ProgramCFDA 84.268 - Federal Direct Student Loans Program Name of Federal AgencyU.S. Department of EducationPass-through EntityN/ACriteria34 CFR Section 668.173(b) states that returns of Title IV Funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the USDE as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew.ConditionIn testing compliance with the requirements for the Return of Title IV funds, we selected the two (2) students who withdrew, dropped out or failed to attend to the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 50% of the sample selected, in which the University failed to return the Title IV funds (Direct Loans) amounting to $9,158.96 within 45 days of determining the withdrawal date.ContextOf the fifty-four (54) cases of students who withdrew, dropped out, or failed to attend to the University, we examined the two (2) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance with the required criteria.Following is a description of each sample and the population from which the samples were drawn for students that received Direct Loans funds during the year ended June 30, 2020: "see schedule of findings and questioned costs chart/table" Cause Withdrawals were processed by the Financial Aid Office, however, they were not properly reported to the Fiscal Resources Office on a timely basis due to human error. EffectAs a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, they could result in reduced availability of federal funds to other students in need of financial assistance.Questioned CostNone.Identification of a repeat findingThis is not a repeat finding from the immediate previous audit.RecommendationThe University needs to improve its processes, including the communication between departments, to ensure that the return of Title IV funds is made within the prescribed period of time.Views of responsible officials and corrective action planThe University management agrees with this finding. Please refer to the corrective action plan on pages 68-75.
Finding No. 2020-004 -Special Test and Provisions -Return of Title IV Funds -TimingContextOf the fifty-four (54) cases of students who withdrew, dropped out, or failed to attend to the University, we examined the two (2) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance with the required criteria. Following is a description of each sample and the population from which the samples were drawn for students that received Direct Loans funds during the year ended June 30, 2020:CauseWithdrawals were processed by the Financial Aid Office; however, they were not properly reported to the Fiscal Resources Office on a timely basis due to human error.EffectAs a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, they could result in reduced availability of federal funds to other students in need of financial assistance. Questioned Cost None. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation the University needs to improve its processes, including the communication between departments, to ensure that the return of Title IV funds is made within the prescribed period of time. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 68-75 Action PlanEvery time a student withdraws from the institution the case will be validated with the registrar's office and all files will be reviewed and process by the financial aid officers in order to comply with the return of Title IV funds (Direct Loans) within 45 days of detennining the withdrawal date.When the Registers office receives the intention of withdrawal from the student, it will inform the Academic Programs to immediately stop all academic activities of the student. When the student starts the withdrawal process the Registrar's Office will provide the information to the Financial Aid Office in order to initiate the analysis of the return of Title IV funds to the USDE. Once the Financial Aid Office detennines the amount of funds to be returned it will be infonned to the Finance Division to proceed with the return of funds within the required period. Dr. Omar Perez, Dean of Administration and Student Affairs
Finding No. 2020-005 - Special Test and Provisions ? Return of Title IV Funds ? Allocation of Funds Federal ProgramStudents Financial Assistance Programs Cluster: CFDA 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA 84.033 - Federal Work-Study ProgramCFDA 84.063 - Federal Pell Grant ProgramCFDA 84.268 - Federal Direct Student Loans Program Name of Federal AgencyU.S. Department of EducationPass-through EntityN/ACriteria34 CFR Section 668.22(i) states that returns of Title IV funds must be distributed in the following order, regardless of the institution?s agreements with other state agencies or private agencies: 1) Unsubsidized Federal Direct Stafford Loans2) Subsidized Federal Direct Stafford Loans3) Federal Direct PLUS4) Federal PELL Grant5) Federal Supplemental Educational Opportunity Grants6) Teacher Education Assistance for College and Higher Education Grants7) Iran and Afghanistan Service Grant Condition In testing compliance with the requirements for the Return of Title IV funds, we selected the two (2) students who withdrew, dropped out or failed to attend to the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 50% of the sample selected, in which the University failed to properly allocate the Direct Loans funds amounting to $9,158.96 in the required order.ContextOf the fifty-four (54) cases of students who withdrew, dropped out, or failed to attend to the University, we examined the two (2) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance with the required criteria. Following is a description of each sample and the population from which the samples were drawn for students that received Direct Loans funds during the year ended June 30, 2020: "see schedule of findings and questioned costs for chart/table" CauseInstances of non-compliance were mainly due to a lack of proper oversight over this requirement.EffectAs a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, they could result in reduced availability of federal funds to other students in need of financial assistance. Questioned CostNone.Identification of a repeat findingThis is not a repeat finding from the immediate previous audit.RecommendationThe University needs to improve its policies and procedures to ensure financial aid personnel is aware of all applicable regulations. In addition, additional review and monitoring procedures should be implemented to ensure that the allocation of the return of Title IV funds is made in the required order.Views of responsible officials and corrective action planThe University management agrees with this finding. Please refer to the corrective action plan on pages 68-75.
Show full finding ▾Hide full finding ▴Finding No. 2020-005 - Special Test and Provisions ? Return of Title IV Funds ? Allocation of Funds Federal ProgramStudents Financial Assistance Programs Cluster: CFDA 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA 84.033 - Federal Work-Study ProgramCFDA 84.063 - Federal Pell Grant ProgramCFDA 84.268 - Federal Direct Student Loans Program Name of Federal AgencyU.S. Department of EducationPass-through EntityN/ACriteria34 CFR Section 668.22(i) states that returns of Title IV funds must be distributed in the following order, regardless of the institution?s agreements with other state agencies or private agencies: 1) Unsubsidized Federal Direct Stafford Loans2) Subsidized Federal Direct Stafford Loans3) Federal Direct PLUS4) Federal PELL Grant5) Federal Supplemental Educational Opportunity Grants6) Teacher Education Assistance for College and Higher Education Grants7) Iran and Afghanistan Service Grant Condition In testing compliance with the requirements for the Return of Title IV funds, we selected the two (2) students who withdrew, dropped out or failed to attend to the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (1) instance, or 50% of the sample selected, in which the University failed to properly allocate the Direct Loans funds amounting to $9,158.96 in the required order.ContextOf the fifty-four (54) cases of students who withdrew, dropped out, or failed to attend to the University, we examined the two (2) students that had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (1) instance of noncompliance with the required criteria. Following is a description of each sample and the population from which the samples were drawn for students that received Direct Loans funds during the year ended June 30, 2020: "see schedule of findings and questioned costs for chart/table" CauseInstances of non-compliance were mainly due to a lack of proper oversight over this requirement.EffectAs a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, they could result in reduced availability of federal funds to other students in need of financial assistance. Questioned CostNone.Identification of a repeat findingThis is not a repeat finding from the immediate previous audit.RecommendationThe University needs to improve its policies and procedures to ensure financial aid personnel is aware of all applicable regulations. In addition, additional review and monitoring procedures should be implemented to ensure that the allocation of the return of Title IV funds is made in the required order.Views of responsible officials and corrective action planThe University management agrees with this finding. Please refer to the corrective action plan on pages 68-75.
Criteria34 CFR Section 668.22(i) stales that returns of Title IV funds must be distributed in the following order, regardless of the institution's agreements with other state agencies or private agencies: 1) Unsubsidized Federal Direct Stafford Loans 2) Subsidized Federal Direct Stafford Loans 3) Federal Direct PLUS 4) Federal PELL Grant 5) Federal Supplemental Educational Opportunity Grants 6) Teacher Education Assistance for College and Higher Education Grants 7) Iran and Afghanistan Service GrantConditionIn testing compliance with the requirements for the Return of Title IV funds, we selected the two (2) students who withdrew, dropped out or failed to attend to the University and had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University. As a result of our testing of these compliance requirements, we noted one (I) instance, or 50% of the sample selected, in which the University failed to properly allocate the Direct Loans funds in the required order.ContextOf the fifty-four (54) cases of students who withdrew, dropped out, or failed to attend to the University, we examined the two (2) students tlrnt had received Title IV funds for the academic period in which the student withdrew, dropped out or failed to attend to the University and noted one (I) instance of noncompliance with the required criteria.CauseInstances of non-compliance were mainly due to a lack of proper oversight over this requirement.EffectAs a result of these conditions, the USDE may issue warnings and/or impose penalties on the University. In addition, they could result in reduced availability of federal funds to other students in need of financial assistance.Action PlanEvery time an R2T4 is required, the financial aid officers will identify the source of funds to be returned. The financial aid oficial will proceed with the documentation and before submitting the transaction the financial aid director will validate the information. Dr. Omar Perez, Dean of Administration and Student Affairs
Finding No. 2020-006 - Special Test and Provisions ? Disbursement to or on Behalf of Students under the Federal Direct Student Loan Program - NotificationsFederal ProgramStudents Financial Assistance Programs Cluster -CFDA 84.268 - Federal Direct Student Loans ProgramName of Federal AgencyU.S. Department of EducationPass-through EntityN/A Criteria34 CFR Section 668.165 (a) states that: before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loans or FFEL Program funds, the notice must indicate which funds are from subsidized loans and which are from unsubsidized loans. Except in the case of a post-withdrawal disbursement made in accordance with 34 CFR Section 668.22(a)(5), if an institution credits a student's account at the institution with Direct Loans, FFEL, Federal Perkins Loan, or Teacher Education Assistance for College and Higher Education Grants (TEACH) Grant Program funds, the institution must notify the student or parent of: ? The anticipated date and amount of the disbursement;? The student's right or parent's right to cancel all or a portion of the Direct Loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds returned to the holder of that loan, the TEACH Grant proceeds returned to the Secretary. However, if the institution releases a check provided by a lender under the FFEL Program, the institution is not required to provide this information; and? The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the Direct Loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement Condition In testing compliance with the requirements for disbursements under the Direct Loans program, we selected sixty (60) participants who received direct loans. During our evaluation of compliance with these requirements, we noted eighteen (18) instances, or 30% of the sample selected, in which the University failed to provide evidence of the written notification sent to the participating students or their parents.ContextOf the three hundred and forty-six (346) students that received direct loans, we selected sixty (60) students and noted eighteen (18) instances of non-compliance with the required criteria. Following is a description of each sample and the population from which the samples were drawn for students that received Direct Loans funds during the year ended June 30, 2020: "see schedule of findings and questioned costs chart/table" Cause Instances of non-compliance with the notification requirements were mainly due to a lack of proper oversight over this requirement. EffectFailure to make the required notifications may be considered by the grantor as a noncompliance with the above-mentioned criteria and could lead to administrative sanctions by the grantor. In addition, as a result of the condition, the student and/or parent may not have received all of the required and pertinent information about the loan disbursement process necessary to reach an informed decision.Questioned CostNone.Identification of a repeat findingThis is not a repeat finding from the immediate previous audit.RecommendationThe University needs to implement additional procedures to ensure that all of the required notifications are sent to the students or parents and that such notifications are made in a timely manner. Management should consider alternative means of communication, including electronic notifications, to assist the University in its compliance with this requirement.Views of responsible officials and corrective action planThe University management agrees with this finding. Please refer to the corrective action plan on pages 68-75.
Show full finding ▾Hide full finding ▴Finding No. 2020-006 - Special Test and Provisions ? Disbursement to or on Behalf of Students under the Federal Direct Student Loan Program - NotificationsFederal ProgramStudents Financial Assistance Programs Cluster -CFDA 84.268 - Federal Direct Student Loans ProgramName of Federal AgencyU.S. Department of EducationPass-through EntityN/A Criteria34 CFR Section 668.165 (a) states that: before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loans or FFEL Program funds, the notice must indicate which funds are from subsidized loans and which are from unsubsidized loans. Except in the case of a post-withdrawal disbursement made in accordance with 34 CFR Section 668.22(a)(5), if an institution credits a student's account at the institution with Direct Loans, FFEL, Federal Perkins Loan, or Teacher Education Assistance for College and Higher Education Grants (TEACH) Grant Program funds, the institution must notify the student or parent of: ? The anticipated date and amount of the disbursement;? The student's right or parent's right to cancel all or a portion of the Direct Loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds returned to the holder of that loan, the TEACH Grant proceeds returned to the Secretary. However, if the institution releases a check provided by a lender under the FFEL Program, the institution is not required to provide this information; and? The procedures and time by which the student or parent must notify the institution that he or she wishes to cancel the Direct Loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement Condition In testing compliance with the requirements for disbursements under the Direct Loans program, we selected sixty (60) participants who received direct loans. During our evaluation of compliance with these requirements, we noted eighteen (18) instances, or 30% of the sample selected, in which the University failed to provide evidence of the written notification sent to the participating students or their parents.ContextOf the three hundred and forty-six (346) students that received direct loans, we selected sixty (60) students and noted eighteen (18) instances of non-compliance with the required criteria. Following is a description of each sample and the population from which the samples were drawn for students that received Direct Loans funds during the year ended June 30, 2020: "see schedule of findings and questioned costs chart/table" Cause Instances of non-compliance with the notification requirements were mainly due to a lack of proper oversight over this requirement. EffectFailure to make the required notifications may be considered by the grantor as a noncompliance with the above-mentioned criteria and could lead to administrative sanctions by the grantor. In addition, as a result of the condition, the student and/or parent may not have received all of the required and pertinent information about the loan disbursement process necessary to reach an informed decision.Questioned CostNone.Identification of a repeat findingThis is not a repeat finding from the immediate previous audit.RecommendationThe University needs to implement additional procedures to ensure that all of the required notifications are sent to the students or parents and that such notifications are made in a timely manner. Management should consider alternative means of communication, including electronic notifications, to assist the University in its compliance with this requirement.Views of responsible officials and corrective action planThe University management agrees with this finding. Please refer to the corrective action plan on pages 68-75.
Finding No. 2020-006 - Special Test and Provisions - Disbursement lo or on Behalf of Students under the Federal Direct Student Loan Program - NotificationsCriteria34 CFR Section 668.165 (a) states that: before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If those funds include Direct Loans or FFEL Program funds, the notice must indicate which funds are from subsidized loans and which are from unsubsidized loans. Except in the case of a post-withdrawal disbursement made in accordance with 34 CFR Section 668.22(a)(5), if an institution credits a student's account at the institution with Dfrect Loans, FFELt Federal Perkins Loan, or Teacher Education Assistance for College and Higher Education Grants (TEACH) Grant Program funds, the institution must notify the student or parent of: The anticipated date and amount of the disbursement; ? The student's right or parent's right to cancel all or a portion of the Direct Loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement and have the loan proceeds returned to the holder of that loan, the TEACH Grant proceeds returned to the Secretary. However, if the institution releases a check provided by a lender under the FFEL Program, the institution is not required to provide this information; and? The procedures and lime by which the student or parent must notify the institution that he or she wishes to cancel the Direct Loan, loan disbursement, TEACH Grant, or TEACH Grant disbursement ConditionIn testing compliance with the requirements for disbursements under the Direct Loans program, we selected sixty (60) participants who received direct loans. During our evaluation of compliance with these requirements, we noted eighteen (18) instances, or 30% of the sample selected, in which the University failed to provide evidence of the written notification sent to the participating students or their parents. Context Of the three hundred and forty-six (346) students that received direct loans, we selected sixty (60) students and noted eighteen (18) instances of non-compliance with the required criteria.ContextOf the three hundred and forty-six (346) students that received direct loans, we selected sixty (60) students and noted eighteen (18) instances of non-compliance with the required criteria.Action PlanThe EDxpress system was programmed for the development and delivery of the award letters. All award letters are already being sent by email and immediatly a copy of the document is included in the student's financial aid record. Dr. Omar Perez, Dean of Administration and Student Affairs
FAC accepted this audit on March 26, 2020 — management decision was due September 26, 2020.
Finding No. 2019-001 - Special Tests and Provisions ? Enrollment Reporting (Significant Deficiency) Federal Program Students Financial Assistance Programs Cluster: CFDA 84.063 - Federal Pell Grant Program CFDA 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education?s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-001 - Special Tests and Provisions ? Enrollment Reporting (Significant Deficiency) - (continued) Criteria ? (continued) The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loan Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-five (25) participants of the Federal Pell Grant Program and/or the Federal Direct Student Loans Program from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended in June 30, 2019. As a result of our test, we noted that for all twenty-one (21) cases that received Student Financial Assistance funds, or 100% of the applicable sample, the University did not report to the NSLDS the students? status changes within the time prescribed by the regulations. Context Of the 787 cases of status changed, we selected twenty-five (25) students and determined that all twenty-one (21) cases that received Student Financial Assistance funds did not comply with the enrollment reporting requirements. Cause Late submissions were due to a misinterpretation in the definition of the effective date that in all instances was interpreted and recorded as the enrollment date. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-001 - Special Tests and Provisions ? Enrollment Reporting (Significant Deficiency) - (continued) Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2018-001. Recommendation The University must ascertain that students? documentation and other information necessary to comply with the federal funds? enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 56- 61.
Show full finding ▾Hide full finding ▴Finding No. 2019-001 - Special Tests and Provisions ? Enrollment Reporting (Significant Deficiency) Federal Program Students Financial Assistance Programs Cluster: CFDA 84.063 - Federal Pell Grant Program CFDA 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria The National Student Loan Data System (NSLDS) is the U.S. Department of Education?s (USDE) central database for federal student aid disbursed under Title IV of the Higher Education Act of 1965 (HEA), as amended. Among other things, NSLDS monitors the programs of attendance and the enrollment status of Title IV aid recipients. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-001 - Special Tests and Provisions ? Enrollment Reporting (Significant Deficiency) - (continued) Criteria ? (continued) The institution determines how often it receives the enrollment reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website, as stated in 34 CFR Section 674.19 for Federal Perkin Loans, 34 CFR 690.83 (b)(2) for Federal Pell Grant Program and 34 CFR section 685.309 for Federal Direct Student Loan Program. A student?s enrollment status determines eligibility for in-school status, deferment, and grace periods, as well as for the payment of interest subsidies to Federal Direct Student Loan Program loan holders by USDE. Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 30 days whenever attendance changes for students, unless a roster will be submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. Condition In testing compliance and internal control over compliance with enrollment reporting, we selected twenty-five (25) participants of the Federal Pell Grant Program and/or the Federal Direct Student Loans Program from the total population who withdrew, graduated, dropped-out or failed to attend to the University during the year ended in June 30, 2019. As a result of our test, we noted that for all twenty-one (21) cases that received Student Financial Assistance funds, or 100% of the applicable sample, the University did not report to the NSLDS the students? status changes within the time prescribed by the regulations. Context Of the 787 cases of status changed, we selected twenty-five (25) students and determined that all twenty-one (21) cases that received Student Financial Assistance funds did not comply with the enrollment reporting requirements. Cause Late submissions were due to a misinterpretation in the definition of the effective date that in all instances was interpreted and recorded as the enrollment date. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-001 - Special Tests and Provisions ? Enrollment Reporting (Significant Deficiency) - (continued) Effect As a result of this condition, the USDE was prevented from the use of accurate reporting data, which is critical for the effective administration of financial aid programs and for USDE budgetary policy analysis. Questioned Cost None. Identification of a repeat finding This is a repeat finding from the immediate previous audit. Finding 2018-001. Recommendation The University must ascertain that students? documentation and other information necessary to comply with the federal funds? enrollment reporting requirements are readily available and up to date, and that all personnel assigned to such processes have the necessary knowledge and experience to ensure full compliance with the applicable regulations. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 56- 61.
Finding No. 2019-001 - Special Tests and Provisions ? Enrollment Reporting Name of Contact Person: Dr. Nereida Diaz Dean of Academic Affairs Corrective Action: By April 29, 2019, we received a letter from the US Department of Education (USDE) concerning some of the findings from the audit report of the Universidad Central del Caribe's (UCC) administration of the Title IV Federal Student Aid Programs. The letter was taken very seriously, and all the requests were addressed. Actions were undertaken and were planned to address concerns within three interconnected scenarios with student reporting including administration, processes and procedures, and professional development. A full file review for all students from the NSLDS data system from July 1, 2017, to June 30, 2018, was completed. We confirmed that from the total cases reviewed, in 52% (790) of the cases data were reported correctly. It was noted that inaccurate data were reported in 48% (728) of the cases and the UCC was able to correct 97% (706) of this inaccurate reporting. Errors mainly were due to a misinterpretation in the definition of the effective date that in all instances was interpreted and recorded as the enrollment date. However, there was still 3% of cases identified with inaccurate data that the UCC was unable to correct in the system. The majority of these cases that were not corrected respond to students that we were unable to find in the NSLDS system. Several initiatives were undertaken and were planned in order to eliminate this finding from future compliance audits, including the following: Administration: 1. A procedure for processing and reporting changes in student enrollment status under Title IV was established (see Appendix 1-UCC Policy for processing and reporting changes in student status enrollment under Title IV). The procedure is in effect since May 22, 2019. The UCC is confident that as procedures, responsibilities, and timelines are clearly adjudicated, all members of the academic community will be observant and cooperative with this important task. The Institutional Effectiveness Office (IEO) will play a key role in monitoring compliance with the procedures. The Office of the Dean of Student Affairs will be responsible for educating all members of the academic community on their responsibilities and procedures. 2. Access (token) to the NSLDS enrollment reporting system was required for: a. The Registrar (to assist with timely and accurate reporting and as a back-up, in case the assistant registrar is unable to perform the task) and for the Dean of Admissions and Student Affairs (for oversight support with the compliance efforts). This activity has not been accomplished, in spite of multiple initiatives and follow-up with NSLDS the token for the Dean of Student Affairs has not been received yet. b. The data manager at the IEO to enable performance of periodic compliance revisions in accuracy and timely reporting, and for the dean of student affairs. 3. The Dean of Academic Affairs instructed all faculty deans, program directors and coordinators to align internal procedures with the recently established procedure for processing and reporting changes in student enrollment status under Title IV. Revised program regulations were executed by June 15, 2019. 4. The UCC's contract with the National Student Clearinghouse (NSC) was signed by both parties and is in effect since May 14, 2019. Progress with the NSC has mainly been done from the part of the UCC in setting the systems and records and processes for viable reporting. Professional development: 1. All employees of the registrar's, financial aid, bursars, and IEO offices, as well as the Dean of Student Affairs and the Dean of Academic Affairs, participated in the Live Internet Webinar - How to Correct Historical Enrollment Reporting in NSLDS that was delivered on Tuesday, June 11, 2019, at 2 p.m. (EST). 2. The Dean of Student Affairs was charged with the development of an initiative to disseminate the procedure for processing and reporting changes in student enrollment status under Title IV, aiming to communicate the importance of these procedures and clarify doubts among dean, faculty, unit designated office/individuals and administrative and support staff. This is an undergoing process and these information dissemination activities are in progress. Continuous compliance monitoring: 1. An internal revision for all students who received Title IV aid from July 1, 2018 to June 30, 2019, was completed between September 17 to October 3, 2019, in order to identify and correct any inaccurate reporting during that period. A 100% of cases reported with error to the NSLDS during academic year 2018-2019 was corrected. Most of the inaccurate information reported responded to incorrect effective status date, incorrect enrollment status, or both. 2. Beginning in academic year 2019-2020 the Dean of Academic Affairs is submitting bimonthly reports to the Office of the President. Actions have been undertaken to: a. Continuously and systematically, update student enrollment status as changes in enrollment occur or are reported to the Office of the Registrar. b. Monitoring of the July 15, 2019 enrollment reporting data batch documents that the March 4, 2019 ? July 17, 2019 reporting period was submitted on time with 93.49% of cases certified with accurate program enrollment. c. Monitoring of the September 19, 2019 enrollment reporting data batch documents that the May, 6, 2019 - September 18, 2019 reporting period was submitted on time with 99.17% of cases certified with accurate program enrollment. d. Monitoring of the January 9, 2020 enrollment reporting data batch documents that the August 5, 2019 - December 19, 2019 reporting period was submitted on time with 100% of cases certified with accurate program enrollment. The UCC is confident that the provisions in place will assure that this finding will not be repeated in future audits. The UCC will keep the internal close monitoring and follow-up. In addition, follow-up will be provided to the progress of the collaboration with the NSC and to the access of the requested tokens to NSLDS.
2018-001
Finding No. 2019-002 - Matching, Level of Effort, Earmarking Federal Program Students Financial Assistance Programs Cluster - CFDA 84.033 - Federal Work-Study Program Name of Federal Agency U.S. Department of Education Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-002 - Matching, Level of Effort, Earmarking ? (continued) Pass-through Entity N/A Criteria 34 CFR 675.18(g) states that an institution must use at least seven percent (7%) of the sum of its initial and supplemental Federal Work-Study allocations for an award year to compensate students employed in community service activities, unless waived by the Secretary of Education if they determine that an institution has demonstrated that enforcing it may cause a hardship for students at the institution. Condition The University used $4,392 out of $100,000 awarded for Federal Work-Study Program (FWSP) to compensate students employed in community service activities, which represents 4.39% of total award. No campus-based waiver was requested for 2019. Context In testing compliance with the requirements for Earmarking under the FWSP, we verified the University?s Fiscal Operations Report and Application to Participate (FISAP) for the amount of work study funds used to compensate students for community service activities, which amounted to $4,392. This represents 4.39% of the initial allocation awarded for work-study for fiscal year 2018-2019. No waiver from the Secretary of Education was requested. Cause Lack of timely review of initial and supplemental FWSP allocation to compensate students. Effect Non-compliance with the above-mentioned criteria could lead to administrative sanctions by the grantor. Questioned Cost None. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-002 - Matching, Level of Effort, Earmarking ? (continued) Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation If compensation to students employed in community service activities under this program the is expected to be under 7% of the initial and supplemental FWSP allocations for the award year, the University must request a waiver from the Secretary of the USDE as per 34 CFR 675.18(g)(2). Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 56- 61.
Show full finding ▾Hide full finding ▴Finding No. 2019-002 - Matching, Level of Effort, Earmarking Federal Program Students Financial Assistance Programs Cluster - CFDA 84.033 - Federal Work-Study Program Name of Federal Agency U.S. Department of Education Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-002 - Matching, Level of Effort, Earmarking ? (continued) Pass-through Entity N/A Criteria 34 CFR 675.18(g) states that an institution must use at least seven percent (7%) of the sum of its initial and supplemental Federal Work-Study allocations for an award year to compensate students employed in community service activities, unless waived by the Secretary of Education if they determine that an institution has demonstrated that enforcing it may cause a hardship for students at the institution. Condition The University used $4,392 out of $100,000 awarded for Federal Work-Study Program (FWSP) to compensate students employed in community service activities, which represents 4.39% of total award. No campus-based waiver was requested for 2019. Context In testing compliance with the requirements for Earmarking under the FWSP, we verified the University?s Fiscal Operations Report and Application to Participate (FISAP) for the amount of work study funds used to compensate students for community service activities, which amounted to $4,392. This represents 4.39% of the initial allocation awarded for work-study for fiscal year 2018-2019. No waiver from the Secretary of Education was requested. Cause Lack of timely review of initial and supplemental FWSP allocation to compensate students. Effect Non-compliance with the above-mentioned criteria could lead to administrative sanctions by the grantor. Questioned Cost None. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-002 - Matching, Level of Effort, Earmarking ? (continued) Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation If compensation to students employed in community service activities under this program the is expected to be under 7% of the initial and supplemental FWSP allocations for the award year, the University must request a waiver from the Secretary of the USDE as per 34 CFR 675.18(g)(2). Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 56- 61.
Finding No. 2019-002 - Matching, Level of Effort, Earmarking Name of Contact Person: Dr. Omar Perez Dean of Admissions and Student Affairs Corrective Action: The Financial Aid Officer (FAO) requested a waiver from the Secretary of the USDE on the second semester of academic year 2018-2019 as per 34 CFR 675.18 (g)(2) for the academic year 2019- 2020. ? On April 2019, an application for a waiver was submitted. Evidence of the community service waiver notification received in May is included. ? The Director of the FAO will submit in the second week of March the waiver. The Director of the FAO immediately will provide evidence of the waiver submission to the Dean of Students and the response to the waiver application from the USDE.
Finding No. 2019-003 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation Federal Program Students Financial Assistance Programs Cluster - CFDA 84.268 - Federal Direct Student Loans Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria A school must submit Federal Pell Grant, TEACH Grant, and Direct Loan disbursement records no later than 15 days after making a disbursement or becoming aware of the need to adjust a student?s disbursement. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-003 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation ? (continued) Condition In testing compliance with the requirements for Borrower Data Transmission and Reconciliation under the Federal Direct Student Loan program (Direct Loans), we selected sixty (60) participants who received Direct Loans. During our evaluation of compliance with these requirements, we noted thirty-seven (37) instances, or 62% of the sample selected, in which the University failed to properly submit the disbursement records to the Common Origination and Disbursement (COD) within 15 days of the disbursement date. Context Of the three hundred and forty-two (342) students that received direct loans, we selected sixty (60) students and noted thirty-seven (37) instances of non-compliance with the required criteria. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement. Effect Failure to submit the required records in a timely manner may be considered by the grantor as a noncompliance with the required criteria and could lead to administrative sanctions by the grantor. Questioned Cost None. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation Management must establish the necessary administrative procedures to ensure the submission of the required information to the COD on a timely basis. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-003 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation ? (continued) Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 56- 61.
Show full finding ▾Hide full finding ▴Finding No. 2019-003 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation Federal Program Students Financial Assistance Programs Cluster - CFDA 84.268 - Federal Direct Student Loans Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria A school must submit Federal Pell Grant, TEACH Grant, and Direct Loan disbursement records no later than 15 days after making a disbursement or becoming aware of the need to adjust a student?s disbursement. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-003 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation ? (continued) Condition In testing compliance with the requirements for Borrower Data Transmission and Reconciliation under the Federal Direct Student Loan program (Direct Loans), we selected sixty (60) participants who received Direct Loans. During our evaluation of compliance with these requirements, we noted thirty-seven (37) instances, or 62% of the sample selected, in which the University failed to properly submit the disbursement records to the Common Origination and Disbursement (COD) within 15 days of the disbursement date. Context Of the three hundred and forty-two (342) students that received direct loans, we selected sixty (60) students and noted thirty-seven (37) instances of non-compliance with the required criteria. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement. Effect Failure to submit the required records in a timely manner may be considered by the grantor as a noncompliance with the required criteria and could lead to administrative sanctions by the grantor. Questioned Cost None. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation Management must establish the necessary administrative procedures to ensure the submission of the required information to the COD on a timely basis. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-003 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation ? (continued) Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 56- 61.
Finding No. 2019-003 - Special Tests and Provisions ? Borrower Data Transmission and Reconciliation Name of Contact Person: Dr. Omar Perez Dean of Admissions and Student Affairs Corrective Action: The FAO will establish the necessary administrative procedures to submit on a timely basis the required information to the COD. The Financial Aid Office immediately started an implementation process, right after the notification of the finding, to establish the necessary administrative procedures to submit on a timely basis the required information to the COD. The following will be the standard operating procedure (SOP) to guarantee the compliance: ? In coordination with the Finance Department, every time disbursements are made, the information will be validated on COD to guarantee the correct information of the student record. This process will be recurrent. ? The Financial Aid Officer will verify the disbursement list provided by the Finance Department and review in COD all cases to guarantee the correct information in the student record. ? The FAO will provide a report to the Director of Financial Aid, attesting that the changes were made within the required time frame of 15 days with a copy to the Dean of Students.
Finding No. 2019-004 - Reporting Federal Program Students Financial Assistance Programs Cluster - CFDA 84.063 - Federal Pell Grant Programs Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria A school must submit Federal Pell Grant, TEACH Grant, and Direct Loan disbursement records no later than 15 days after making a disbursement or becoming aware of the need to adjust a student?s disbursement. Condition In testing compliance with the requirements for reporting under the Federal Pell Grant program, we selected thirteen (13) participants who received Pell grant. During our evaluation of compliance with these requirements, we noted five (5) instances, or 38% of the sample selected, in which the University failed to properly submit the disbursement records to the COD within 15 days of the disbursement date. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-004 ? Reporting ? (continued) Context Of the hundred and sixteen (116) students that received PELL grant, we selected thirteen (13) students and noted five (5) instances of non-compliance with the required criteria. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement. Effect Failure to submit the required records in a timely manner may be considered by the grantor as a noncompliance with the required criteria and could lead to administrative sanctions by the grantor. Questioned Cost None. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation Management must establish the necessary administrative procedures to ensure the submission of the required information to the COD on a timely basis.. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 56- 61.
Show full finding ▾Hide full finding ▴Finding No. 2019-004 - Reporting Federal Program Students Financial Assistance Programs Cluster - CFDA 84.063 - Federal Pell Grant Programs Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria A school must submit Federal Pell Grant, TEACH Grant, and Direct Loan disbursement records no later than 15 days after making a disbursement or becoming aware of the need to adjust a student?s disbursement. Condition In testing compliance with the requirements for reporting under the Federal Pell Grant program, we selected thirteen (13) participants who received Pell grant. During our evaluation of compliance with these requirements, we noted five (5) instances, or 38% of the sample selected, in which the University failed to properly submit the disbursement records to the COD within 15 days of the disbursement date. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-004 ? Reporting ? (continued) Context Of the hundred and sixteen (116) students that received PELL grant, we selected thirteen (13) students and noted five (5) instances of non-compliance with the required criteria. Cause Instances of non-compliance were mainly due to a lack of proper oversight over this requirement. Effect Failure to submit the required records in a timely manner may be considered by the grantor as a noncompliance with the required criteria and could lead to administrative sanctions by the grantor. Questioned Cost None. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation Management must establish the necessary administrative procedures to ensure the submission of the required information to the COD on a timely basis.. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 56- 61.
Finding No. 2019-004 ? Reporting Name of Contact Person: Dr. Omar Perez Dean of Admissions and Student Affairs Corrective Action: The Financial Aid Office immediately started an implementation process, right after the notification of the finding, to establish the necessary administrative procedures to submit on a timely basis requirement information to the COD. The following will be the SOP to guarantee the compliance: ? In coordination with the Finance Department, every time disbursements are made, the information will be validated on COD to guarantee the correct information of the student record. This process will be recurrent. ? The Financial Aid Officer will verify the disbursement list provided by the Finance Department and review in COD all cases to guarantee the correct information in the student record. ? The FAO will provide a report to the Director of Financial Aid, attesting that the changes were made within the required time frame of 15 days with a copy to the Dean of Students.
Finding No. 2019-005 - Special Test and Provisions ? Gramm-Leach-Bliley Act Federal Program Students Financial Assistance Programs Cluster: CFDA 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA 84.033 - Federal Work-Study Program CFDA 84.063 - Federal Pell Grant Program CFDA 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria The Gramm-Leach-Bliley Act (the Act) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV- eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Act (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the Department of Education and the Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the USDE or otherwise obtained in support of the administration of the federal student financial aid programs. (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). As required by the Act, the University shall develop, implement, and maintain a comprehensive information security program that contains administrative, technical, and physical safeguards that are appropriate to its size and complexity, the nature and scope of its activities, and the sensitivity of any customer information at issue. Such safeguards shall be reasonably designed to achieve the following objectives: 1. Ensure the security and confidentiality of customer information; 2. Protect against any anticipated threats or hazards to the security or integrity of such information; and 3. Protect against unauthorized access to or use of such information that could result in substantial harm or inconvenience to any customer. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-005 - Special Test and Provisions ? Gramm-Leach-Bliley Act ? (continued) Condition The University has not developed and implemented a formal information security program specifically designed to address the requirements of the Act, including a formal information security risk assessment. Cause As a new requirement for 2019, the University has not performed a formal information security risk assessment to evaluate its exposure to potential cyber-security risks as required by the Act. Context The University is not in compliance with the requirements of the Act. Effect The University might not able to identify and mitigate potential cyber-security risks and vulnerabilities, which could endanger the privacy and confidentiality of personal records and information. Questioned Cost None. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation The University needs to perform a formal information security risk assessment in order to identify potential risks and vulnerabilities that might exist within its information technology environment in order to properly develop and implement policies and procedures to ensure the protection of personal information and compliance with the requirements of the Act. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 56-61.
Show full finding ▾Hide full finding ▴Finding No. 2019-005 - Special Test and Provisions ? Gramm-Leach-Bliley Act Federal Program Students Financial Assistance Programs Cluster: CFDA 84.007 - Federal Supplemental Educational Opportunity Grants (FSEOG) CFDA 84.033 - Federal Work-Study Program CFDA 84.063 - Federal Pell Grant Program CFDA 84.268 - Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria The Gramm-Leach-Bliley Act (the Act) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV- eligible institutions that participate in Title IV Educational Assistance Programs as ?financial institutions? and subject to the Act (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the Department of Education and the Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the USDE or otherwise obtained in support of the administration of the federal student financial aid programs. (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). As required by the Act, the University shall develop, implement, and maintain a comprehensive information security program that contains administrative, technical, and physical safeguards that are appropriate to its size and complexity, the nature and scope of its activities, and the sensitivity of any customer information at issue. Such safeguards shall be reasonably designed to achieve the following objectives: 1. Ensure the security and confidentiality of customer information; 2. Protect against any anticipated threats or hazards to the security or integrity of such information; and 3. Protect against unauthorized access to or use of such information that could result in substantial harm or inconvenience to any customer. Part III ? Findings and Questioned Costs Relating to Federal Awards ? (continued) Finding No. 2019-005 - Special Test and Provisions ? Gramm-Leach-Bliley Act ? (continued) Condition The University has not developed and implemented a formal information security program specifically designed to address the requirements of the Act, including a formal information security risk assessment. Cause As a new requirement for 2019, the University has not performed a formal information security risk assessment to evaluate its exposure to potential cyber-security risks as required by the Act. Context The University is not in compliance with the requirements of the Act. Effect The University might not able to identify and mitigate potential cyber-security risks and vulnerabilities, which could endanger the privacy and confidentiality of personal records and information. Questioned Cost None. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation The University needs to perform a formal information security risk assessment in order to identify potential risks and vulnerabilities that might exist within its information technology environment in order to properly develop and implement policies and procedures to ensure the protection of personal information and compliance with the requirements of the Act. Views of responsible officials and corrective action plan The University management agrees with this finding. Please refer to the corrective action plan on pages 56-61.
Finding No. 2019-005 - Special Test and Provisions ? Gramm-Leach-Bliley Act Name of Contact Person: Dr. Nereida Diaz Dean of Academic Affairs Corrective Action: The UCC has in place several systems, actions or processes to: 1) ensure employees have access only to the relevant data needed to conduct University business; 2) ensure the security and confidentiality of student records and information; 3) safeguard and prevent unauthorized access to personally identifiable financial records and information maintained by the university; 4) comply with existing university policies, standards, guidelines and procedures; and 5) to comply with applicable federal, state and local regulations. Examples of these provisions are discussed below: 1. Access and confidentiality of student records: The UCC has policies and procedures in place for the secure and confidential maintenance of student information (see Appendix 2-for Federal Educational Rights and Privacy Act (FERPA) and Appendix 3-Policy regarding the student records. The Registrar' s Office is the custodian of student academic records and registration. They strictly adhere to the FERPA regulations and restrictions about data sharing, based on the institutional procedures in place for managing student information with the utmost care, confidentiality, and security. Student records are administered through Jenzabar? (integrated information system). Security layers are in place and faculty and students must request access to records following the established procedures. Personnel at the Registrar's office is trained and supported by the IT staff on the management and safe interchange of data. Interchange of data with the US DoE occur through encrypted data procedures (for example NSLDS enrollment reporting). 2. Access to employee records: The Office of Human Resources is the custodian of the University?s personnel records. Information and data are protected under the procedures established by the office in compliance with the norms of access and use of official personnel records. The norms establish the procedures and mechanisms to request and grant access to personnel official record. The human resources staff is trained on the best practices to safeguard and protect confidentiality of data in UCC employee' s records. Personnel records that are also administered through Jenzabar? (integrated information system) share the same security layers that are established for student records. Security layers are in place to safeguard and protect confidentiality of this information. 3. Protection of confidentiality and data: The University, specifically the Learning and Information Resources Center (LIRC) that houses the IT systems is engaged in a twofold strategy to assure prevention and security of the data through the articulation of the following activities: a. Development of a macro model for the integration of policies, norms and data security procedures for the University as a whole. This intends to put together and consolidate dispersed cybersecurity initiatives that are already in place in an easy to access format. b. Revision of the Policy for the Protection of Confidentiality and Data. This work was initiated in 2017 and followed in 2018. It is currently under refinement with the expectation to be ready for final approval by the end of this winter (February 2020). To finalize this initiative, the LIRC developed a cybersecurity committee and is seeking and receiving the assistance of external consultants. In conclusion, the University is confident that with the completion and refinement of the macro model for the integration of policies, norms and data security procedures and the refinement of the Policy for the Protection of Confidentiality and Data by the end of this winter (February 28, 2020) compliance with this requirement will be evidenced. Implementation of the Policy for the Protection of Confidentiality and Data by March l, 2020 will consolidate a formal process and system for an Information Security Program in full compliance with the Gramm-Leach-Bliley Act requirements.
FAC accepted this audit on March 27, 2019 — management decision was due September 27, 2019.
GSA_MIGRATION
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2017-002
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2017-003
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FAC accepted this audit on March 25, 2018 — management decision was due September 25, 2018.
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2016-002
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2016-003
FAC accepted this audit on March 29, 2017 — management decision was due September 29, 2017.
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