Audit 298262

Finding Number: 2023-003 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Return of Title IV Funds Criteria 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 the attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs. The amount earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is on or after the completion of 60 percent. Otherwise, the percentage earned by the student is equal to the percentage (less than 60 percent) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date institution determines that the student withdrew. Condition We noted two transactions selected for testing whereas the return of payment check was issued 45 days after the withdrawal date of the student. Cause Processed and controls over the return of payment requirements are not in place to ensure that the University issues payments timely. Effect The University did not comply with return of title IV funds requirements, which could lead to funds disallowance. Questioned Costs Not applicable. Context Our sample consisted of 40 items from a population that consisted of 789 withdrawn students. Identification as a repeat finding, if applicable Not applicable. Recommendation We recommend the University establishes procedures to ensure payments are issued timely and accurately, and that compliance with timeliness requirements is monitored. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-004 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Enrollment Reporting Criteria Under the Pell Grant and Education Department (ED) loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No.1845-0035). The institution determines the Enrollment Reporting roster file with the default set at 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, spreadsheet submittal, or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. 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 FFEL Program loan holders by ED. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported in the next updated Enrollment Reporting Roster file (due within 60 days). These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. As explained in the NSLDS Enrollment Reporting Guide, the Enrollment Reporting roster file is due within 15 days from the creation of the file that is placed in the institution’s SAIG (PELL, 34 CFR section 690.83(b)(2); FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Per 34 CFR Section 682.610 for the Federal Family Education Loan (FFEL) and 34 CFR Section 685.309 for the Direct Loans Program, schools must complete and return within 60 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by U.S Department of Education (ED) via National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition We noted that for 22 students selected for testing, the status change reported to the National Student Loan Data System (NSLDS) was past the 60 days established threshold. Cause Processes and controls over the reporting of the student status change to the Department of Education are not in place to ensure that the University timely complies with this requirement. Effect This condition prevents the University from reporting a student’s status in a timely manner to the NSLDS, which can cause funds being awarded to individuals who are not entitled to receive student financial assistance. Also, an incorrect enrollment status and/or status date reported could cause a student's loan to be inappropriately delayed in being converted in repayment status. Questioned Costs Not applicable. Context Our sample consisted of 60 items (out of a population of 4,201 students that had a reduction or increase in attendance levels, dropped out, withdrew, never attended, or requested graduation for fiscal year 2023). Since several exceptions were identified, we concluded that the items do represent systematic occurrences. Identification as a repeat finding, if applicable 2022-002 Recommendation We recommend that the University establishes procedures to ensure that enrollment status changes are updated and accurately reported in a timely manner in the NSLDS database. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-003 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Return of Title IV Funds Criteria 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 the attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs. The amount earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is on or after the completion of 60 percent. Otherwise, the percentage earned by the student is equal to the percentage (less than 60 percent) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date institution determines that the student withdrew. Condition We noted two transactions selected for testing whereas the return of payment check was issued 45 days after the withdrawal date of the student. Cause Processed and controls over the return of payment requirements are not in place to ensure that the University issues payments timely. Effect The University did not comply with return of title IV funds requirements, which could lead to funds disallowance. Questioned Costs Not applicable. Context Our sample consisted of 40 items from a population that consisted of 789 withdrawn students. Identification as a repeat finding, if applicable Not applicable. Recommendation We recommend the University establishes procedures to ensure payments are issued timely and accurately, and that compliance with timeliness requirements is monitored. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-004 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Enrollment Reporting Criteria Under the Pell Grant and Education Department (ED) loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No.1845-0035). The institution determines the Enrollment Reporting roster file with the default set at 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, spreadsheet submittal, or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. 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 FFEL Program loan holders by ED. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported in the next updated Enrollment Reporting Roster file (due within 60 days). These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. As explained in the NSLDS Enrollment Reporting Guide, the Enrollment Reporting roster file is due within 15 days from the creation of the file that is placed in the institution’s SAIG (PELL, 34 CFR section 690.83(b)(2); FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Per 34 CFR Section 682.610 for the Federal Family Education Loan (FFEL) and 34 CFR Section 685.309 for the Direct Loans Program, schools must complete and return within 60 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by U.S Department of Education (ED) via National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition We noted that for 22 students selected for testing, the status change reported to the National Student Loan Data System (NSLDS) was past the 60 days established threshold. Cause Processes and controls over the reporting of the student status change to the Department of Education are not in place to ensure that the University timely complies with this requirement. Effect This condition prevents the University from reporting a student’s status in a timely manner to the NSLDS, which can cause funds being awarded to individuals who are not entitled to receive student financial assistance. Also, an incorrect enrollment status and/or status date reported could cause a student's loan to be inappropriately delayed in being converted in repayment status. Questioned Costs Not applicable. Context Our sample consisted of 60 items (out of a population of 4,201 students that had a reduction or increase in attendance levels, dropped out, withdrew, never attended, or requested graduation for fiscal year 2023). Since several exceptions were identified, we concluded that the items do represent systematic occurrences. Identification as a repeat finding, if applicable 2022-002 Recommendation We recommend that the University establishes procedures to ensure that enrollment status changes are updated and accurately reported in a timely manner in the NSLDS database. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-003 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Return of Title IV Funds Criteria 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 the attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs. The amount earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is on or after the completion of 60 percent. Otherwise, the percentage earned by the student is equal to the percentage (less than 60 percent) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date institution determines that the student withdrew. Condition We noted two transactions selected for testing whereas the return of payment check was issued 45 days after the withdrawal date of the student. Cause Processed and controls over the return of payment requirements are not in place to ensure that the University issues payments timely. Effect The University did not comply with return of title IV funds requirements, which could lead to funds disallowance. Questioned Costs Not applicable. Context Our sample consisted of 40 items from a population that consisted of 789 withdrawn students. Identification as a repeat finding, if applicable Not applicable. Recommendation We recommend the University establishes procedures to ensure payments are issued timely and accurately, and that compliance with timeliness requirements is monitored. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-004 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Enrollment Reporting Criteria Under the Pell Grant and Education Department (ED) loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No.1845-0035). The institution determines the Enrollment Reporting roster file with the default set at 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, spreadsheet submittal, or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. 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 FFEL Program loan holders by ED. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported in the next updated Enrollment Reporting Roster file (due within 60 days). These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. As explained in the NSLDS Enrollment Reporting Guide, the Enrollment Reporting roster file is due within 15 days from the creation of the file that is placed in the institution’s SAIG (PELL, 34 CFR section 690.83(b)(2); FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Per 34 CFR Section 682.610 for the Federal Family Education Loan (FFEL) and 34 CFR Section 685.309 for the Direct Loans Program, schools must complete and return within 60 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by U.S Department of Education (ED) via National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition We noted that for 22 students selected for testing, the status change reported to the National Student Loan Data System (NSLDS) was past the 60 days established threshold. Cause Processes and controls over the reporting of the student status change to the Department of Education are not in place to ensure that the University timely complies with this requirement. Effect This condition prevents the University from reporting a student’s status in a timely manner to the NSLDS, which can cause funds being awarded to individuals who are not entitled to receive student financial assistance. Also, an incorrect enrollment status and/or status date reported could cause a student's loan to be inappropriately delayed in being converted in repayment status. Questioned Costs Not applicable. Context Our sample consisted of 60 items (out of a population of 4,201 students that had a reduction or increase in attendance levels, dropped out, withdrew, never attended, or requested graduation for fiscal year 2023). Since several exceptions were identified, we concluded that the items do represent systematic occurrences. Identification as a repeat finding, if applicable 2022-002 Recommendation We recommend that the University establishes procedures to ensure that enrollment status changes are updated and accurately reported in a timely manner in the NSLDS database. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-003 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Return of Title IV Funds Criteria 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 the attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs. The amount earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is on or after the completion of 60 percent. Otherwise, the percentage earned by the student is equal to the percentage (less than 60 percent) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date institution determines that the student withdrew. Condition We noted two transactions selected for testing whereas the return of payment check was issued 45 days after the withdrawal date of the student. Cause Processed and controls over the return of payment requirements are not in place to ensure that the University issues payments timely. Effect The University did not comply with return of title IV funds requirements, which could lead to funds disallowance. Questioned Costs Not applicable. Context Our sample consisted of 40 items from a population that consisted of 789 withdrawn students. Identification as a repeat finding, if applicable Not applicable. Recommendation We recommend the University establishes procedures to ensure payments are issued timely and accurately, and that compliance with timeliness requirements is monitored. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-004 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Enrollment Reporting Criteria Under the Pell Grant and Education Department (ED) loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No.1845-0035). The institution determines the Enrollment Reporting roster file with the default set at 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, spreadsheet submittal, or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. 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 FFEL Program loan holders by ED. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported in the next updated Enrollment Reporting Roster file (due within 60 days). These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. As explained in the NSLDS Enrollment Reporting Guide, the Enrollment Reporting roster file is due within 15 days from the creation of the file that is placed in the institution’s SAIG (PELL, 34 CFR section 690.83(b)(2); FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Per 34 CFR Section 682.610 for the Federal Family Education Loan (FFEL) and 34 CFR Section 685.309 for the Direct Loans Program, schools must complete and return within 60 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by U.S Department of Education (ED) via National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition We noted that for 22 students selected for testing, the status change reported to the National Student Loan Data System (NSLDS) was past the 60 days established threshold. Cause Processes and controls over the reporting of the student status change to the Department of Education are not in place to ensure that the University timely complies with this requirement. Effect This condition prevents the University from reporting a student’s status in a timely manner to the NSLDS, which can cause funds being awarded to individuals who are not entitled to receive student financial assistance. Also, an incorrect enrollment status and/or status date reported could cause a student's loan to be inappropriately delayed in being converted in repayment status. Questioned Costs Not applicable. Context Our sample consisted of 60 items (out of a population of 4,201 students that had a reduction or increase in attendance levels, dropped out, withdrew, never attended, or requested graduation for fiscal year 2023). Since several exceptions were identified, we concluded that the items do represent systematic occurrences. Identification as a repeat finding, if applicable 2022-002 Recommendation We recommend that the University establishes procedures to ensure that enrollment status changes are updated and accurately reported in a timely manner in the NSLDS database. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-002 Federal Program Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – 21.027 COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Family Planning Services - 93.217 Category Internal Control Internal Control over Compliance Requirement Reporting Criteria Recipients must use the standard reporting forms and submit them in a timely manner as prescribed by the federal award agency and/or the Compliance Supplement. Condition It was observed that there are ineffective internal controls in place to ensure timely filing of reports within the established timeline. Specifically, there is a lack of formalized procedures and monitoring mechanisms to track and enforce adherence to reporting deadlines. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports timely. Effect The University could not provide evidence supporting the internal control operated effectively during the period. Lack of proper controls increases the risk of delayed reporting, potentially leading to regulatory non-compliance. Questioned Costs Not applicable. Context The programs mentioned above have different frequencies and types of reports. When combined, reports for the programs totaled 97 from which we selected 10 samples to test. Identification as a repeat finding, if applicable 2022-003 and 2022-004 (internal control portion only) Recommendation We recommend the University implements internal controls and/or monitoring procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence of the control operation. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-002 Federal Program Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – 21.027 COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Family Planning Services - 93.217 Category Internal Control Internal Control over Compliance Requirement Reporting Criteria Recipients must use the standard reporting forms and submit them in a timely manner as prescribed by the federal award agency and/or the Compliance Supplement. Condition It was observed that there are ineffective internal controls in place to ensure timely filing of reports within the established timeline. Specifically, there is a lack of formalized procedures and monitoring mechanisms to track and enforce adherence to reporting deadlines. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports timely. Effect The University could not provide evidence supporting the internal control operated effectively during the period. Lack of proper controls increases the risk of delayed reporting, potentially leading to regulatory non-compliance. Questioned Costs Not applicable. Context The programs mentioned above have different frequencies and types of reports. When combined, reports for the programs totaled 97 from which we selected 10 samples to test. Identification as a repeat finding, if applicable 2022-003 and 2022-004 (internal control portion only) Recommendation We recommend the University implements internal controls and/or monitoring procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence of the control operation. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-002 Federal Program Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – 21.027 COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Family Planning Services - 93.217 Category Internal Control Internal Control over Compliance Requirement Reporting Criteria Recipients must use the standard reporting forms and submit them in a timely manner as prescribed by the federal award agency and/or the Compliance Supplement. Condition It was observed that there are ineffective internal controls in place to ensure timely filing of reports within the established timeline. Specifically, there is a lack of formalized procedures and monitoring mechanisms to track and enforce adherence to reporting deadlines. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports timely. Effect The University could not provide evidence supporting the internal control operated effectively during the period. Lack of proper controls increases the risk of delayed reporting, potentially leading to regulatory non-compliance. Questioned Costs Not applicable. Context The programs mentioned above have different frequencies and types of reports. When combined, reports for the programs totaled 97 from which we selected 10 samples to test. Identification as a repeat finding, if applicable 2022-003 and 2022-004 (internal control portion only) Recommendation We recommend the University implements internal controls and/or monitoring procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence of the control operation. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-002 Federal Program Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – 21.027 COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Family Planning Services - 93.217 Category Internal Control Internal Control over Compliance Requirement Reporting Criteria Recipients must use the standard reporting forms and submit them in a timely manner as prescribed by the federal award agency and/or the Compliance Supplement. Condition It was observed that there are ineffective internal controls in place to ensure timely filing of reports within the established timeline. Specifically, there is a lack of formalized procedures and monitoring mechanisms to track and enforce adherence to reporting deadlines. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports timely. Effect The University could not provide evidence supporting the internal control operated effectively during the period. Lack of proper controls increases the risk of delayed reporting, potentially leading to regulatory non-compliance. Questioned Costs Not applicable. Context The programs mentioned above have different frequencies and types of reports. When combined, reports for the programs totaled 97 from which we selected 10 samples to test. Identification as a repeat finding, if applicable 2022-003 and 2022-004 (internal control portion only) Recommendation We recommend the University implements internal controls and/or monitoring procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence of the control operation. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-002 Federal Program Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – 21.027 COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Family Planning Services - 93.217 Category Internal Control Internal Control over Compliance Requirement Reporting Criteria Recipients must use the standard reporting forms and submit them in a timely manner as prescribed by the federal award agency and/or the Compliance Supplement. Condition It was observed that there are ineffective internal controls in place to ensure timely filing of reports within the established timeline. Specifically, there is a lack of formalized procedures and monitoring mechanisms to track and enforce adherence to reporting deadlines. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports timely. Effect The University could not provide evidence supporting the internal control operated effectively during the period. Lack of proper controls increases the risk of delayed reporting, potentially leading to regulatory non-compliance. Questioned Costs Not applicable. Context The programs mentioned above have different frequencies and types of reports. When combined, reports for the programs totaled 97 from which we selected 10 samples to test. Identification as a repeat finding, if applicable 2022-003 and 2022-004 (internal control portion only) Recommendation We recommend the University implements internal controls and/or monitoring procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence of the control operation. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-002 Federal Program Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – 21.027 COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Family Planning Services - 93.217 Category Internal Control Internal Control over Compliance Requirement Reporting Criteria Recipients must use the standard reporting forms and submit them in a timely manner as prescribed by the federal award agency and/or the Compliance Supplement. Condition It was observed that there are ineffective internal controls in place to ensure timely filing of reports within the established timeline. Specifically, there is a lack of formalized procedures and monitoring mechanisms to track and enforce adherence to reporting deadlines. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports timely. Effect The University could not provide evidence supporting the internal control operated effectively during the period. Lack of proper controls increases the risk of delayed reporting, potentially leading to regulatory non-compliance. Questioned Costs Not applicable. Context The programs mentioned above have different frequencies and types of reports. When combined, reports for the programs totaled 97 from which we selected 10 samples to test. Identification as a repeat finding, if applicable 2022-003 and 2022-004 (internal control portion only) Recommendation We recommend the University implements internal controls and/or monitoring procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence of the control operation. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-003 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Return of Title IV Funds Criteria 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 the attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs. The amount earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is on or after the completion of 60 percent. Otherwise, the percentage earned by the student is equal to the percentage (less than 60 percent) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date institution determines that the student withdrew. Condition We noted two transactions selected for testing whereas the return of payment check was issued 45 days after the withdrawal date of the student. Cause Processed and controls over the return of payment requirements are not in place to ensure that the University issues payments timely. Effect The University did not comply with return of title IV funds requirements, which could lead to funds disallowance. Questioned Costs Not applicable. Context Our sample consisted of 40 items from a population that consisted of 789 withdrawn students. Identification as a repeat finding, if applicable Not applicable. Recommendation We recommend the University establishes procedures to ensure payments are issued timely and accurately, and that compliance with timeliness requirements is monitored. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-004 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Enrollment Reporting Criteria Under the Pell Grant and Education Department (ED) loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No.1845-0035). The institution determines the Enrollment Reporting roster file with the default set at 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, spreadsheet submittal, or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. 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 FFEL Program loan holders by ED. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported in the next updated Enrollment Reporting Roster file (due within 60 days). These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. As explained in the NSLDS Enrollment Reporting Guide, the Enrollment Reporting roster file is due within 15 days from the creation of the file that is placed in the institution’s SAIG (PELL, 34 CFR section 690.83(b)(2); FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Per 34 CFR Section 682.610 for the Federal Family Education Loan (FFEL) and 34 CFR Section 685.309 for the Direct Loans Program, schools must complete and return within 60 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by U.S Department of Education (ED) via National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition We noted that for 22 students selected for testing, the status change reported to the National Student Loan Data System (NSLDS) was past the 60 days established threshold. Cause Processes and controls over the reporting of the student status change to the Department of Education are not in place to ensure that the University timely complies with this requirement. Effect This condition prevents the University from reporting a student’s status in a timely manner to the NSLDS, which can cause funds being awarded to individuals who are not entitled to receive student financial assistance. Also, an incorrect enrollment status and/or status date reported could cause a student's loan to be inappropriately delayed in being converted in repayment status. Questioned Costs Not applicable. Context Our sample consisted of 60 items (out of a population of 4,201 students that had a reduction or increase in attendance levels, dropped out, withdrew, never attended, or requested graduation for fiscal year 2023). Since several exceptions were identified, we concluded that the items do represent systematic occurrences. Identification as a repeat finding, if applicable 2022-002 Recommendation We recommend that the University establishes procedures to ensure that enrollment status changes are updated and accurately reported in a timely manner in the NSLDS database. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-003 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Return of Title IV Funds Criteria 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 the attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs. The amount earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is on or after the completion of 60 percent. Otherwise, the percentage earned by the student is equal to the percentage (less than 60 percent) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date institution determines that the student withdrew. Condition We noted two transactions selected for testing whereas the return of payment check was issued 45 days after the withdrawal date of the student. Cause Processed and controls over the return of payment requirements are not in place to ensure that the University issues payments timely. Effect The University did not comply with return of title IV funds requirements, which could lead to funds disallowance. Questioned Costs Not applicable. Context Our sample consisted of 40 items from a population that consisted of 789 withdrawn students. Identification as a repeat finding, if applicable Not applicable. Recommendation We recommend the University establishes procedures to ensure payments are issued timely and accurately, and that compliance with timeliness requirements is monitored. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-004 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Enrollment Reporting Criteria Under the Pell Grant and Education Department (ED) loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No.1845-0035). The institution determines the Enrollment Reporting roster file with the default set at 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, spreadsheet submittal, or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. 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 FFEL Program loan holders by ED. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported in the next updated Enrollment Reporting Roster file (due within 60 days). These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. As explained in the NSLDS Enrollment Reporting Guide, the Enrollment Reporting roster file is due within 15 days from the creation of the file that is placed in the institution’s SAIG (PELL, 34 CFR section 690.83(b)(2); FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Per 34 CFR Section 682.610 for the Federal Family Education Loan (FFEL) and 34 CFR Section 685.309 for the Direct Loans Program, schools must complete and return within 60 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by U.S Department of Education (ED) via National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition We noted that for 22 students selected for testing, the status change reported to the National Student Loan Data System (NSLDS) was past the 60 days established threshold. Cause Processes and controls over the reporting of the student status change to the Department of Education are not in place to ensure that the University timely complies with this requirement. Effect This condition prevents the University from reporting a student’s status in a timely manner to the NSLDS, which can cause funds being awarded to individuals who are not entitled to receive student financial assistance. Also, an incorrect enrollment status and/or status date reported could cause a student's loan to be inappropriately delayed in being converted in repayment status. Questioned Costs Not applicable. Context Our sample consisted of 60 items (out of a population of 4,201 students that had a reduction or increase in attendance levels, dropped out, withdrew, never attended, or requested graduation for fiscal year 2023). Since several exceptions were identified, we concluded that the items do represent systematic occurrences. Identification as a repeat finding, if applicable 2022-002 Recommendation We recommend that the University establishes procedures to ensure that enrollment status changes are updated and accurately reported in a timely manner in the NSLDS database. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-003 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Return of Title IV Funds Criteria 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 the attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs. The amount earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is on or after the completion of 60 percent. Otherwise, the percentage earned by the student is equal to the percentage (less than 60 percent) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date institution determines that the student withdrew. Condition We noted two transactions selected for testing whereas the return of payment check was issued 45 days after the withdrawal date of the student. Cause Processed and controls over the return of payment requirements are not in place to ensure that the University issues payments timely. Effect The University did not comply with return of title IV funds requirements, which could lead to funds disallowance. Questioned Costs Not applicable. Context Our sample consisted of 40 items from a population that consisted of 789 withdrawn students. Identification as a repeat finding, if applicable Not applicable. Recommendation We recommend the University establishes procedures to ensure payments are issued timely and accurately, and that compliance with timeliness requirements is monitored. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-004 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Enrollment Reporting Criteria Under the Pell Grant and Education Department (ED) loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No.1845-0035). The institution determines the Enrollment Reporting roster file with the default set at 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, spreadsheet submittal, or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. 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 FFEL Program loan holders by ED. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported in the next updated Enrollment Reporting Roster file (due within 60 days). These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. As explained in the NSLDS Enrollment Reporting Guide, the Enrollment Reporting roster file is due within 15 days from the creation of the file that is placed in the institution’s SAIG (PELL, 34 CFR section 690.83(b)(2); FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Per 34 CFR Section 682.610 for the Federal Family Education Loan (FFEL) and 34 CFR Section 685.309 for the Direct Loans Program, schools must complete and return within 60 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by U.S Department of Education (ED) via National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition We noted that for 22 students selected for testing, the status change reported to the National Student Loan Data System (NSLDS) was past the 60 days established threshold. Cause Processes and controls over the reporting of the student status change to the Department of Education are not in place to ensure that the University timely complies with this requirement. Effect This condition prevents the University from reporting a student’s status in a timely manner to the NSLDS, which can cause funds being awarded to individuals who are not entitled to receive student financial assistance. Also, an incorrect enrollment status and/or status date reported could cause a student's loan to be inappropriately delayed in being converted in repayment status. Questioned Costs Not applicable. Context Our sample consisted of 60 items (out of a population of 4,201 students that had a reduction or increase in attendance levels, dropped out, withdrew, never attended, or requested graduation for fiscal year 2023). Since several exceptions were identified, we concluded that the items do represent systematic occurrences. Identification as a repeat finding, if applicable 2022-002 Recommendation We recommend that the University establishes procedures to ensure that enrollment status changes are updated and accurately reported in a timely manner in the NSLDS database. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-003 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Return of Title IV Funds Criteria 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 the attendance, the institution must determine the amount of Title IV aid earned by the student as of the student’s withdrawal date. If the total amount of Title IV assistance earned by the student is less than the amount that was disbursed to the student or on his or her behalf as of the date of the institution’s determination that the student withdrew, the difference must be returned to the Title IV programs. The amount earned Title IV grant or loan assistance is calculated by determining the percentage of Title IV grant or loan assistance that has been earned by the student and applying that percentage to the total amount of Title IV grant or loan assistance that was or could have been disbursed to the student for the payment period or period of enrollment as of the student’s withdrawal date. A student earns 100 percent if his or her withdrawal date is on or after the completion of 60 percent. Otherwise, the percentage earned by the student is equal to the percentage (less than 60 percent) of the payment period or period of enrollment that was completed as of the student’s withdrawal date. The unearned amount of Title IV assistance to be returned is calculated by subtracting the amount of Title IV assistance earned by the student from the amount of Title IV aid that was disbursed to the student as of the date of the institution’s determination that the student withdrew (34 CFR 668.22(e)). Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to ED as soon as possible, but no later than 45 days after the date institution determines that the student withdrew. Condition We noted two transactions selected for testing whereas the return of payment check was issued 45 days after the withdrawal date of the student. Cause Processed and controls over the return of payment requirements are not in place to ensure that the University issues payments timely. Effect The University did not comply with return of title IV funds requirements, which could lead to funds disallowance. Questioned Costs Not applicable. Context Our sample consisted of 40 items from a population that consisted of 789 withdrawn students. Identification as a repeat finding, if applicable Not applicable. Recommendation We recommend the University establishes procedures to ensure payments are issued timely and accurately, and that compliance with timeliness requirements is monitored. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-004 Program Student Financial Assistance (SFA) Cluster - Various ALN Category Internal Control / Compliance Compliance Requirement Special Tests and Provisions – Enrollment Reporting Criteria Under the Pell Grant and Education Department (ED) loan programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS (OMB No.1845-0035). The institution determines the Enrollment Reporting roster file with the default set at 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, spreadsheet submittal, or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. 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 FFEL Program loan holders by ED. Enrollment Reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported in the next updated Enrollment Reporting Roster file (due within 60 days). These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. As explained in the NSLDS Enrollment Reporting Guide, the Enrollment Reporting roster file is due within 15 days from the creation of the file that is placed in the institution’s SAIG (PELL, 34 CFR section 690.83(b)(2); FFEL, 34 CFR section 682.610; Direct Loan, 34 CFR section 685.309). Per 34 CFR Section 682.610 for the Federal Family Education Loan (FFEL) and 34 CFR Section 685.309 for the Direct Loans Program, schools must complete and return within 60 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (SAIG) mailboxes sent by U.S Department of Education (ED) via National Student Loan Data System (NSLDS) (OMB No. 1845-0035). The institution determines how often it receives the Enrollment Reporting roster file with the default set at a minimum of every 60 days. Once received, the institution must update for changes in student status, report the date the enrollment status was effective, enter the new anticipated completion date, and submit the changes electronically through the batch method or the NSLDS website. Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Condition We noted that for 22 students selected for testing, the status change reported to the National Student Loan Data System (NSLDS) was past the 60 days established threshold. Cause Processes and controls over the reporting of the student status change to the Department of Education are not in place to ensure that the University timely complies with this requirement. Effect This condition prevents the University from reporting a student’s status in a timely manner to the NSLDS, which can cause funds being awarded to individuals who are not entitled to receive student financial assistance. Also, an incorrect enrollment status and/or status date reported could cause a student's loan to be inappropriately delayed in being converted in repayment status. Questioned Costs Not applicable. Context Our sample consisted of 60 items (out of a population of 4,201 students that had a reduction or increase in attendance levels, dropped out, withdrew, never attended, or requested graduation for fiscal year 2023). Since several exceptions were identified, we concluded that the items do represent systematic occurrences. Identification as a repeat finding, if applicable 2022-002 Recommendation We recommend that the University establishes procedures to ensure that enrollment status changes are updated and accurately reported in a timely manner in the NSLDS database. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-002 Federal Program Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – 21.027 COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Family Planning Services - 93.217 Category Internal Control Internal Control over Compliance Requirement Reporting Criteria Recipients must use the standard reporting forms and submit them in a timely manner as prescribed by the federal award agency and/or the Compliance Supplement. Condition It was observed that there are ineffective internal controls in place to ensure timely filing of reports within the established timeline. Specifically, there is a lack of formalized procedures and monitoring mechanisms to track and enforce adherence to reporting deadlines. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports timely. Effect The University could not provide evidence supporting the internal control operated effectively during the period. Lack of proper controls increases the risk of delayed reporting, potentially leading to regulatory non-compliance. Questioned Costs Not applicable. Context The programs mentioned above have different frequencies and types of reports. When combined, reports for the programs totaled 97 from which we selected 10 samples to test. Identification as a repeat finding, if applicable 2022-003 and 2022-004 (internal control portion only) Recommendation We recommend the University implements internal controls and/or monitoring procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence of the control operation. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-002 Federal Program Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – 21.027 COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Family Planning Services - 93.217 Category Internal Control Internal Control over Compliance Requirement Reporting Criteria Recipients must use the standard reporting forms and submit them in a timely manner as prescribed by the federal award agency and/or the Compliance Supplement. Condition It was observed that there are ineffective internal controls in place to ensure timely filing of reports within the established timeline. Specifically, there is a lack of formalized procedures and monitoring mechanisms to track and enforce adherence to reporting deadlines. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports timely. Effect The University could not provide evidence supporting the internal control operated effectively during the period. Lack of proper controls increases the risk of delayed reporting, potentially leading to regulatory non-compliance. Questioned Costs Not applicable. Context The programs mentioned above have different frequencies and types of reports. When combined, reports for the programs totaled 97 from which we selected 10 samples to test. Identification as a repeat finding, if applicable 2022-003 and 2022-004 (internal control portion only) Recommendation We recommend the University implements internal controls and/or monitoring procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence of the control operation. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-002 Federal Program Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – 21.027 COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Family Planning Services - 93.217 Category Internal Control Internal Control over Compliance Requirement Reporting Criteria Recipients must use the standard reporting forms and submit them in a timely manner as prescribed by the federal award agency and/or the Compliance Supplement. Condition It was observed that there are ineffective internal controls in place to ensure timely filing of reports within the established timeline. Specifically, there is a lack of formalized procedures and monitoring mechanisms to track and enforce adherence to reporting deadlines. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports timely. Effect The University could not provide evidence supporting the internal control operated effectively during the period. Lack of proper controls increases the risk of delayed reporting, potentially leading to regulatory non-compliance. Questioned Costs Not applicable. Context The programs mentioned above have different frequencies and types of reports. When combined, reports for the programs totaled 97 from which we selected 10 samples to test. Identification as a repeat finding, if applicable 2022-003 and 2022-004 (internal control portion only) Recommendation We recommend the University implements internal controls and/or monitoring procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence of the control operation. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-002 Federal Program Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – 21.027 COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Family Planning Services - 93.217 Category Internal Control Internal Control over Compliance Requirement Reporting Criteria Recipients must use the standard reporting forms and submit them in a timely manner as prescribed by the federal award agency and/or the Compliance Supplement. Condition It was observed that there are ineffective internal controls in place to ensure timely filing of reports within the established timeline. Specifically, there is a lack of formalized procedures and monitoring mechanisms to track and enforce adherence to reporting deadlines. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports timely. Effect The University could not provide evidence supporting the internal control operated effectively during the period. Lack of proper controls increases the risk of delayed reporting, potentially leading to regulatory non-compliance. Questioned Costs Not applicable. Context The programs mentioned above have different frequencies and types of reports. When combined, reports for the programs totaled 97 from which we selected 10 samples to test. Identification as a repeat finding, if applicable 2022-003 and 2022-004 (internal control portion only) Recommendation We recommend the University implements internal controls and/or monitoring procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence of the control operation. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-002 Federal Program Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – 21.027 COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Family Planning Services - 93.217 Category Internal Control Internal Control over Compliance Requirement Reporting Criteria Recipients must use the standard reporting forms and submit them in a timely manner as prescribed by the federal award agency and/or the Compliance Supplement. Condition It was observed that there are ineffective internal controls in place to ensure timely filing of reports within the established timeline. Specifically, there is a lack of formalized procedures and monitoring mechanisms to track and enforce adherence to reporting deadlines. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports timely. Effect The University could not provide evidence supporting the internal control operated effectively during the period. Lack of proper controls increases the risk of delayed reporting, potentially leading to regulatory non-compliance. Questioned Costs Not applicable. Context The programs mentioned above have different frequencies and types of reports. When combined, reports for the programs totaled 97 from which we selected 10 samples to test. Identification as a repeat finding, if applicable 2022-003 and 2022-004 (internal control portion only) Recommendation We recommend the University implements internal controls and/or monitoring procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence of the control operation. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.

Finding Number: 2023-002 Federal Program Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – 21.027 COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Family Planning Services - 93.217 Category Internal Control Internal Control over Compliance Requirement Reporting Criteria Recipients must use the standard reporting forms and submit them in a timely manner as prescribed by the federal award agency and/or the Compliance Supplement. Condition It was observed that there are ineffective internal controls in place to ensure timely filing of reports within the established timeline. Specifically, there is a lack of formalized procedures and monitoring mechanisms to track and enforce adherence to reporting deadlines. Cause Processes and controls over the reporting requirements are not in place to ensure that the University complies with the submission of required reports timely. Effect The University could not provide evidence supporting the internal control operated effectively during the period. Lack of proper controls increases the risk of delayed reporting, potentially leading to regulatory non-compliance. Questioned Costs Not applicable. Context The programs mentioned above have different frequencies and types of reports. When combined, reports for the programs totaled 97 from which we selected 10 samples to test. Identification as a repeat finding, if applicable 2022-003 and 2022-004 (internal control portion only) Recommendation We recommend the University implements internal controls and/or monitoring procedures to ensure reports are completed and filed timely, and that such procedures include requirements for the supporting documentation to be retained as evidence of the control operation. Management’s Response The University of Puerto Rico concurs with this finding. Management response is included in a separate document.