Universidad Pentecostal Mizpa IncNon-Profit

HEERF INSTITUTIONAL AID SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUE) YEAR ENDED JUNE 30, 2023 CASH MANAGEMENT FINDING NO. 2023-002 – TIME ELAPSING BETWEEN THE TRANSFER OF FUNDS CRITERIA Schools must minimize the time elapsing between the transfer of funds from ED and disbursement by the school for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a school uses. Under the advance payment method, payment is made to the school before the school disburses the funds for program purposes (2 CFR section 200.3). Some schools’ grants may have been placed on Route Pay or Stop Pay Status, as indicated by a notification the grantee would have received from ED. This requires ED approval of a spending plan prior to the grantee drawing down funds or the submission of single requests with documentation. For CRRSAA HEERF II and ARP HEERF III, the Certification and Agreement and/or Supplemental Agreement indicate that Student Aid (ALN 84.425E) should be disbursed within 15 calendar days of the drawdown from ED’s grant management system (G5), while Institutional Aid Portion, (a)(2), and (a)(3) funds (all other ALNs) should be disbursed within 3 calendar days of the drawdown from G5. CONDITION During our field work in the cash management area, we noted funds that were requested to G-5 but not disbursed by UPM to minimize the time elapsing between the transfer of funds and disbursement as follows: Description Dates Amount Funds receceived from G-5 on June 8, 2022 6/8/2022 $610,710.35 Funds disbursed during 2022-2023 Fiscal year 2022-23 (525,362.27) Available balance from funds received in 6/8/2022 6/30/2023 $ 75,348.08 Funds receceived from G-5 on June 22, 2023 6/22/2023 $319,251.71 Funds disbursed at the end of fiscal year 2022-2023 6/30/2023 ( 45,000) Available balance from funds received in 6/22/2023 6/30/2023 $274,251.71 HEERF INSTITUTIONAL AID SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUE) YEAR ENDED JUNE 30, 2023 CASH MANAGEMENT (CONTINUE) FINDING NO. 2023-002 – TRANSFER OF FUNDS BEYOND THE REQUIRED TIME LIMITS EFFECT The drawdowns of Federal funds made by UPM not minimized the time elapsing between transfer of funds and the disbursement by the university according to regulations. QUESTIONED COSTS $0.00 CAUSE This situation occurred due to UPM did not make adequate follow up to the cash advances received from G-5 RECOMMENDATION The University should reinforce the procedures the drawdown of funds to comply with the regulation applicable for the transfer of funds through the G-5 system. VIEWS OF RESPONSIBLE OFFICIALS See the Corrective Action Plan for details of action required.

HEERF INSTITUTIONAL AID SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUE) YEAR ENDED JUNE 30, 2023 PROCUREMENT SUSPENSION AND DEBARMENT FINDING NO. 2023-003 – PROCUREMENT SUSPENSION AND DEBARMENT CRITERIA Suspension and Debarment Schools are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 C.F.R.§ 180.220. All non-procurement transactions entered by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 C.F.R. § 180.215. When a school enters into a covered transaction with an entity at a lower tier, the school must verify that the entity, as defined in 2 C.F.R. § 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management Exclusions maintained by the General Services Administration and available at https://www.sam.gov/SAM/ (click on Search Record, then click on Advanced Search- Exclusions) (Note: The OMB guidance at 2 C.F.R. part 180 and agency implementing regulations still refer to the System for Award Management Exclusions as the Excluded Parties List System), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 C.F.R. § 180.300). Schools receiving contracts from the federal government are required to comply with the contract clause at FAR 52.209-6 before entering into a subcontract that will exceed $30,000, other than a subcontract for a commercially available off-the-shelf item. Criteria: 2 C.F.R. §§ 200.318 through 200.326 2 C.F.R. Part 180 48 C.F.R. Subpart 2.1 48 C.F.R. § 9.405-2(b) 48 C.F.R. § 52.209-6 HEERF INSTITUTIONAL AID SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUE) YEAR ENDED JUNE 30, 2023 PROCUREMENT SUSPENSION AND DEBARMENT FINDING NO. 2023-003 – PROCUREMENT SUSPENSION AND DEBARMENT (CONTINUE) CRITERIA (CONTINUE) Improper payment means: (1) Any payment that should not have been made or that was made in an incorrect amount under statutory, contractual, administrative, or other legally applicable requirements. (i) Incorrect amounts are overpayments or underpayments that are made to eligible recipients (including inappropriate denials of payment or service, any payment that does not account for credit for applicable discounts, payments that are for an incorrect amount, and duplicate payments). An improper payment also includes any payment that was made to an ineligible recipient or for an ineligible good or service, or payments for goods or services not received. Note 1 to paragraph (1)(i) of this definition. Applicable discounts are only those discounts where it is both advantageous and within the agency's control to claim them. (ii) When an agency's review is unable to discern whether a payment was proper as a result of insufficient or lack of documentation, this payment should also be considered an improper payment. When establishing documentation requirements for payments, agencies should ensure that all documentation requirements are necessary and should refrain from imposing additional burdensome documentation requirements. Code of Federal regulations Title II Subtitle A Chapter II Part 200 Subpart A-Acronyms Section 200.1 HEERF INSTITUTIONAL AID SCHEDULE OF FINDINGS AND QUESTIONED COSTS (CONTINUE) YEAR ENDED JUNE 30, 2023 PROCUREMENT SUSPENSION AND DEBARMENT FINDING NO. 2023-003 – PROCUREMENT SUSPENSION AND DEBARMENT (CONTINUE) CONDITION We examined one hundred percent (100%) of the disbursed made and charged to HEERF Instutional Aid for the fiscal year 2022-2023 and noted the following: 1) UPM did not have documentation related Schools are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 2) UPM made five (5) payments for $100,406.71 in advance for goods or services not received at the disbursement date. EFFECT UPM did not comply with the regulations and internal controls procedures to made disbursements before received goods or services. QUESTIONED COSTS $100,406.71 CAUSE The institution did not follow the institutional procedures to make disbursements before received goods or services according to regulations and institution procedures. RECOMMENDATION The Institution should reinforce the established procedures and adhere to them before any payment is made for goods or services. The amount of $100,406.71 should be reimbursed to the U.S. Department of Education. In addition, UPM should be included in its procedures steps to adopting regulations, to verify that the vendor entity is not suspended or debarred or otherwise excluded from participating in the transaction. VIEWS OF RESPONSIBLE OFFICIALS See the Corrective Action Plan for details of action required.

FINDING NO. 2020-001 ? REPORTING STUDENT ENROLLMENT DATA TO NSLDS CRITERIA Student enrollment information is important, and all schools participating or approved to participate in the FSA programs must have online enrollment access and have some arrangement to report student enrollment data to the National Student Loan Data System (NSLDS) through an enrollment roster file. Enrollment information is used to determine if the student is still considered in school, must be moved into repayment, or is eligible for an in-school deferment. Program-level enrollment data is also used to determine a student?s eligibility for Direct Subsidized Loans. For students moving into repayment, the out-of-school status effective date determines when the grace period begins and how soon a student must begin repaying loan funds. You?re required to report changes in the student?s enrollment status, the effective date of the status, and an anticipated completion date. You must report enrollment status at both the school and program level. For this purpose, an academic program is defined as the combination of your school?s Office of Postsecondary Education Identification (OPEID) number and the program?s Classification of Instructional Program (CIP) code, credential level, and published program length. When a student is enrolled in more than one major (or comparable designation under your school?s academic policies), each is considered an academic program and is reported separately whether the student receives separate degrees or certificates for each major or only receives one for completing the requirements for all majors. Enrollment in a minor is not a separate program and therefore would not be reported as such. Report a student?s ?active enrollment status? (full-time, three-quarter time, half-time, and less than half-time) based on the total number of credit or clock hours in which he or she is enrolled at the institution, regardless of whether specific credits apply to the academic program being reported. Student Financial Aid Handbook Volume 2?School Eligibility and Operations 2019?2020 Chapter 3?FSA Administrative & Related Requirements Page 2-66 CONDITION During our field work we noted, that in two (2) of twenty-five students tested changes in the student?s enrollment status were incorrectly reported or not reported. EFFECT Non-compliance with regulations QUESTIONED COSTS $0.00 CAUSE The Financial Aid Office did not follow adequately its internal procedures to report changes in the student?s enrollment status. RECOMMENDATIONS The University should modify its procedures to ensure that changes on student?s enrollment are reported in compliance with federal regulations. VIEWS OF RESPONSIBLE OFFICIALS See the Corrective Action Plan for details of action required.

FINDING NO. 2020-2 ? RETURNS OF TITLE IV FUNDS CRITERIA Withdrawals: After the 60% point in the payment period or period of enrollment, a student has earned 100% of the Title IV funds the student was scheduled to receive during the period. For a student who withdraws after the 60% point-in-time, there are no unearned funds. However, a school must still determine whether the student is eligible for a post-withdrawal disbursement (PWD). 34 CFR 668.22 Student Financial Aid Handbook Volume 5?Withdrawals and the Return of Title IV Funds, 2019?2020 Chapter 1?Withdrawals and the Return of Title IV Funds Page 5-3 Coordinating Oficial: All the information the school receives and any changes processed by any University office that might affect a student?s FSA eligibility are communicated to the coordinating official and by her to the financial aid office. Student Financial Aid Handbook Volume 2?School Eligibility and Operations 2019?2020 Chapter 3?FSA Administrative & Related Requirements Page 2-50 CONDITION During the Student Eligibility and Disbursement Test of twenty (25) students files, we noted one (1) instance the student was officially withdrew from the institution, however, this withdrawal was not reported to the SFA Office by Registrar Office. The student withdrawal passed the 60 % point in the payment period. EFFECT The University did not comply with Federal regulations. QUESTIONED COSTS $0.00 CAUSE The Registrar Office did not notify to the SFA Office that the student was officially withdrew from the University on a timely basis. RECOMMENDATIONS The Institution should be reinforcing the withdrawals procedures and establish a close coordination among the offices regarding the Return Title IV, in order to comply with the federal regulations. VIEWS OF RESPONSIBLE OFFICIALS Included in the Institution?s Corrective Action Plan.

FINDING NO. 2020-003 ? INFORMATION SECURITY PROGRAM CRITERIA The Gramm-Leach-Bliley Act (Public Law 106-102) 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 Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department 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)). The Department of Education provides additional information about cybersecurity requirements at https://ifap.ed.gov/eannouncements/Cyber.html. CONDITION During our field work we interviewed the Administration Dean in relation to the designation of an individual to coordinate the information security and perform risk assessment that addresses the areas indicated in the regulations. However, the designation of individual and the risk assessment evaluation are still pending to performed. EFFECT Non-compliance with regulations QUESTIONED COSTS $0.00 CAUSE The Institution management is unaware the regulations requirements. RECOMMENDATIONS The University must comply with established regulations and designate human resources to develop, coordinate an information security program and conduct a risk assessment that addresses the areas identified in the regulations. VIEWS OF RESPONSIBLE OFFICIALS See the Corrective Action Plan for details of action required.

FINDING NO. 2020-004 ? WEB PAGE CRITERIA Web Dissemination: A school may meet the requirements for the general disclosures and the EADA, security, and fire safety reports by posting the information online. ? Enrolled students or current employees?the school may post the information on an Internet website or an intranet website that is reasonably accessible to its students and employees. ? Prospective students or prospective employees?the school may post the information on an Internet website. A school that uses Internet or intranet disclosure for this purpose must include in its annual notice to enrolled students the exact electronic address of the information and a statement that the school will provide a paper copy of the information on request. With Internet or intranet distribution of the security and fire safety reports to current employees, a school must distribute to them by October 1 of each year a notice that includes a statement of the reports? availability, the exact electronic address at which they are posted, a brief description of their contents, and a statement that the school will provide a paper copy of the reports upon request. The same information must be included in a notice to prospective students and employees if a school decides to use the Web to provide annual security or fire safety reports to them. The difference is that there is no annual date for distribution of this notice; also note that the school must use an Internet, rather than an intranet, site. CONDITION During our field audit work we noted that the information disseminated in the university web page needs to be updated. For example the institutional policies posted in the web page were not updated since various years ago. EFFECT Non-compliance with regulations QUESTIONED COSTS $0.00 CAUSE The University management did not update the web page information as requested by the regulations. RECOMMENDATIONS The University needs to update the web page information to comply with the regulations for Web dissemination. VIEWS OF RESPONSIBLE OFFICIALS See the Corrective Action Plan for details of action required.

UNIIVERSIDAD PENTECOSTAL MIZPA INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED JUNE 30, 2019 FEDERAL PROGRAM FINDINGS AND QUESTIONED COSTS (CONTINUED) SPECIAL TESTS AND PROVISIONS (CONTINUED) FINDING NO. 2019-003 ? RETURNING AN UNCLAIMED TITLE IV CREDIT BALANCES CRITERIA TIME FRAME FOR RETURNING AN UNCLAIMED TITLE IV CREDIT BALANCE A school must return to the Department any Title IV funds, except FWS program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, a school is required to return only the federal portion of the payroll disbursement. If an EFT to a student?s or parent?s financial account is rejected, or a check to a student or parent is returned, a school may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the school does not make another attempt, the funds must be returned to the Department before the end of this 45-day period. The school must cease all attempts to disburse the funds and return them no later than 240 days after the date it issued the first check. All unclaimed credit balances must be returned?there is no de minimis amount. CONDITION a) During the bank reconciliations procedures for the year ended June 30, 2019, we noted that institution has eight (8) unclaimed credit balances checks outstanding amounting $669.58, for more than 240 days after the date it issued the first in the bank account xxx-xxx162. EFFECT Non-compliance with regulations and did not follow the established procedures to returning an unclaimed Title IV credit balances. QUESTIONED COSTS $669.58 UNIVERSIDAD PENTECOSTAL MIZPA INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED JUNE 30, 2019 FEDERAL PROGRAM FINDINGS AND QUESTIONED COSTS (CONTINUED) SPECIAL TESTS AND PROVISIONS (CONTINUED) FINDING NO. 2019-003 ? RETURNING AN UNCLAIMED TITLE IV CREDIT BALANCES (CONTINUED) CAUSE The Institution did not follow the established procedures for unclaimed credit balances and its returns to DOE. In addition the banl reconciliations were not prepared in timely basis. RECOMMENDATIONS The Institution should be reinforcing the established procedures for returning an unclaimed credit balances in order to comply with the federal regulations. In addition, the institution must have to perform internal review of this condition and returned the exact amount to DOE as stated in the regulations. In addition, the Institution must return to DOE the amount of $669.58. VIEWS OF RESPONSIBLE OFFICIALS See the Corrective Action Plan for details of action required.

UNIVERSIDAD PENTECOSTAL MIZPA INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED JUNE 30, 2019 FEDERAL PROGRAM FINDINGS AND QUESTIONED COSTS (CONTINUED) SPECIAL TESTS AND PROVISIONS (CONTINUED) FINDING NO. 2019-004 ? INFORMATION SECURITY PROGRAM CRITERIA The Gramm-Leach-Bliley Act (Public Law 106-102) 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 Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Under an institution?s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department 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)) The Department of Education provides additional information about cybersecurity requirements at https://ifap.ed.gov/eannouncements/Cyber.html. CONDITION During our field work we intervied Administrative Dean related to the designation an individual to coordinate the information security program and perform risk assessment that addresses the areas noted in the regulations. However, the designation and the risk assessment still pending to performed. EFFECT Non-compliance with regulations QUESTIONED COSTS $0.00 UNIVERSIDAD PENTECOSTAL MIZPA INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED JUNE 30, 2019 FEDERAL PROGRAM FINDINGS AND QUESTIONED COSTS (CONTINUED) SPECIAL TESTS AND PROVISIONS (CONTINUED) FINDING NO. 2019-004 ? INFORMATION SECURITY PROGRAM (CONTINUED) CAUSE The Institution management unknow the regualtions requirements. RECOMMENDATIONS The Institution needs to comply with the regulations for the designation an individual to coordinate the information security program and perform risk assessment that addresses the areas noted in the regulations. VIEWS OF RESPONSIBLE OFFICIALS See the Corrective Action Plan for details of action required.

UNIVERSIDAD PENTECOSTAL MIZPA INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED JUNE 30, 2019 FEDERAL PROGRAM FINDINGS AND QUESTIONED COSTS (CONTINUED) SPECIAL TESTS AND PROVISIONS (CONTINUED) FINDING NO. 2019-005 ? WEB PAGE CRITERIA Web dissemination A school may meet the requirements for the general disclosures and the EADA, security, and fire safety reports by posting the information online. ? Enrolled students or current employees?the school may post the information on an Internet website or an intranet website that is reasonably accessible to its students and employees. ? Prospective students or prospective employees?the school may post the information on an Internet website. A school that uses Internet or intranet disclosure for this purpose must include in its annual notice to enrolled students the exact electronic address of the information and a statement that the school will provide a paper copy of the information on request. With Internet or intranet distribution of the security and fire safety reports to current employees, a school must distribute to them by October 1 of each year a notice that includes a statement of the reports? availability, the exact electronic address at which they are posted, a brief description of their contents, and a statement that the school will provide a paper copy of the reports upon request. The same information must be included in a notice to prospective students and employees if a school decides to use the Web to provide annual security or fire safety reports to them. The difference is that there is no annual date for distribution of this notice; also note that the school must use an Internet, rather than an intranet, site. UNIVERSIDAD PENTECOSTAL MIZPA INC. SCHEDULE OF FINDINGS AND QUESTIONED COSTS YEAR ENDED JUNE 30, 2019 FEDERAL PROGRAM FINDINGS AND QUESTIONED COSTS (CONTINUED) SPECIAL TESTS AND PROVISIONS (CONTINUED) FINDING NO. 2019-005 ? WEB PAGE CONDITION During our field audit work we noted that the information dissemnate in the university web page needs updated. For example the institutional catalog and policies posted in the web page were not upated since some years ago. In addition the 2018-19 anual security report was not presented in the university web page. EFFECT Non-compliance with regulations QUESTIONED COSTS $0.00 CAUSE The Institution management did not update the web page information as requested by the regulations. RECOMMENDATIONS The Institution needs to updated web page information to comply with the regulations for Web dissemination. VIEWS OF RESPONSIBLE OFFICIALS See the Corrective Action Plan for details of action required.

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