Federal programs: Federal Pell Grant Program; Federal Direct Loan Program
Finding Type: Significant Deficiency
Compliance requirement: Special tests and provisions - Return of Title IV Funds:
Condition and context.
In testing compliance with the return of Title IV requirement applicable after a student begins
attendance, we selected a sample of three (3) participants of the Title IV Student Financial
Assistance (SFA) programs who received $5,389.00 in SFA funds from a population of twelve
(12) students who withdrew, dropped out, or failed to attend to the Institution, who received
$21,167.00 in Title IV (SFA) funds. Our sample was a statistically valid sample.
We noted in two (2) cases of our sample that the Institution failed to determine that the student
withdrew within 14 days after the student's last date of attendance as determined by the Institution
from its attendance records.
Criteria
Withdrawals and the Return of Title IV Funds 2027-2022 of the Financial Student Aid Handbook
(Volume 5) establishes that if a student who began attendance and has not officially withdrawn
fails to earn a passing grade in at least one course offered over an entire period, the institution
must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the
institution can document that the student completed the period. Keep in mind that a grade of
"incomplete" is not considered a passing grade or successful completion.
Dear Colleague Letter GEN-04-03 (Revised November 2004) — states in item 2 that an institution
may have a grading policy as follows: F (Failing) Awarded to students who complete the course
but fail to achieve the course objectives. U (Unauthorized Incomplete) Awarded to students who
did not officially withdraw from the course, but who failed to participate in course activities through
the end of the period. It is used when, in the opinion of the instructor, completed assignments or
course activities or both were insufficient to make normal evaluation of academic performance
possible.
A student who did not officially withdraw and did not receive either a passing grade or an 'F' in at
least one course must be considered to have unofficially withdrawn. Important: Compliance audits
and program reviews may examine whether a school accurately assigns failing grades to students
if the school uses its grading policy to determine whether a student with failing grades has
unofficially withdrawn.
34 CFR 668.22 "Treatment of title IV funds when a student withdraws", section (a) General, (1)
states that when a recipient of title IV grant or loan assistance withdraws from an institution during
a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of title IV grant or loan assistance that the student earned as of the
student's withdrawal date in accordance with paragraph (e) of this section.
Page | 37
Universidad Teológica del Caribe, Inc.
Schedule of Findings and Questioned Costs (continued)
July 31, 2023
Also, in (b) "Withdrawal date for a student who withdraws from an institution that is required to
take attendance", section (1) states that for purposes of this section, for a student who ceases
attendance at an institution that is required to take attendance, including a student who does not
return from an approved leave of absence, as defined in paragraph (d) of this section, or a student
who takes a leave of absence that does not meet the requirements of paragraph (d) of this section,
the student's withdrawal date is the last date of academic attendance as determined by the
institution from its attendance records and section (2) states that an institution must document a
student's withdrawal date determined in accordance with paragraph (b)(1) of this section and
maintain the documentation as of the date of the institution's determination that the student
withdrew.34 CFR 668.22 (j), "Timeframe for the return of title IV funds", establishes that: (1) An
institution must return the amount of title IV funds for which it is responsible as soon as possible
but no later than 45 days after the date of the institution's determination that the student withdrew.
The timeframe for returning funds is further described in § 668.173(b); (2) For an institution that
is not required to take attendance, an institution must determine the withdrawal date for a student
who withdraws without providing notification to the institution no later than 30 days after the end
of the earlier of the - (i) Payment period or period of enrollment, as appropriate.
34 CFR 668.173 (b), "Timely return of title IV, HEA program funds", establishes that in accordance
with procedures established by the secretary, an institution returns unearned title IV, HEA
program funds timely if - (1) the institution deposits or transfers the funds into the bank account it
maintains under § 668.163 no later than 45 days after the date it determines that the student
withdrew.
Dear Colleague Letter GEN-04-03 (Revised November 2004) - Subject: Return of Title IV Aid
states that Institutions are expected to have procedures to determine when a student's absence
is a withdrawal. Institutions that are required to take attendance are expected to have a procedure
in place for routinely monitoring attendance records to determine in a timely manner when a
student withdraws. Except in unusual instances, at an institution that is required to take
attendance, they would expect that the date of the institution's determination that the student
withdrew would be no later than 14 days after the student's withdrawal date - the last date of
academic attendance as determined by the institution from its attendance records (34 CFR
668.22(b)(1)).
Cause
The Institution's internal controls for tracking and calculating the return of title IV funds of the
students who withdrew, drop out or stopped attending the Institution failed to identify and process
these cases as required and on a timely basis.
Effect
The failure to correct these deficiencies which have been cited in prior audits may result in the
Institution being referred to the Department's Administrative Actions and Appeals Service Group
(AAASG) for possible adverse action. Such action may include a fine, or the limitation,
suspension, or termination of the eligibility of the Institution. Such action may also include the
revocation of the institution's program participation agreement (if provisional), or, if the Institution
has an application pending for renewal of its certification, denial of that application.
Page | 38
Universidad Teológica del Caribe, Inc.
Schedule of Findings and Questioned Costs (continued)
July 31, 2023
Questioned costs
Less than $25,000, if any.
Identification as a Repeat Finding
A finding related to this compliance requirement was included in the prior year audit as Finding
No. 2021-003.
Recommendations
We recommend the Institution to improve its procedures to ascertain that the return of Title IV
funds requirements is properly followed and unearned funds are properly calculated and returned
timely to the USDE. Also, the Institution should consider creating a position of compliance officer.
Educational institutions must meet and observe a wide variety of guidelines and regulations set
by both government agencies and nongovernmental associations to receive financial support and
maintain accreditation. A school's compliance officer spreads awareness of policies, coordinates
programs to promote the observation of guidelines and reports to a top-level administrator.
Views of Responsible Officials
Refer to the Institutional comments included in the Corrective Action Plan.
Institutional Comments on Findings and Recommendations:
Compliance Requirements – Applicable After a Student Begins Attendance:
The institution agrees with the auditors on this finding in which there were two (2) cases where
the auditors noted that the institution failed to determine that the students withdrew within fourteen
(14) days after the student’s last day of attendance.
In one (1) of the two (2) cases the Date of Determination was twenty-two (22) days after the Last
Day of Attendance and in the second case, the Date of Determination was Three (3) days after
the Last Day of Attendance.
All funds due to the Department, (for the first case $682.00 of Unsub. Direct Loan funds and in
the second case $974.22 of Federal Pell Grant funds), were returned within the forty-five (45)
days required timeframe as of the Date of Determination of each case.
This process was evidenced to the auditors for their records.
Actions Taken or Planned:
The institution is fully aware of the Return of Title IV funds (R2T4) reporting requirements and
deadlines.
The issue related to this finding was identified as a lack in some Faculty notifying student
absences within the fourteen (14) day timeframe to process an R2T4 in a timely manner as
required.
Although this issue was already discussed with them by the Dean of Academic Affairs, an
additional follow up meeting would be held to remind them of the importance in monitoring student
Page | 39
Universidad Teológica del Caribe, Inc.
Schedule of Findings and Questioned Costs (continued)
July 31, 2023
attendance and notifying student absences to the Registrar office within the required timeframes
to fully comply with the R2T4 reporting requirements.
Status of Corrective Actions on Prior Findings:
The issue as related to this finding occurred in the past audit.
Federal programs: Federal Pell Grant Program; Federal Direct Loan Program
Compliance requirement: Special tests and provisions - Enrollment reporting
Condition and context.
During our enrollment reporting test, for a statistically valid sample of ten (10) students from a
population of thirty-five (35) records that had a reduction or increase in attendance levels,
graduated, withdrew, dropped out, or enrolled but never attended during the audit period, we
noted the following deficiencies:
In three (3) cases, we noted that the Institution did not report the correct enrollment status for
these students.
a. In one (1) case, the student enrollment status was notified as being enrolled in six (6)
credits instead of being a withdrawal (W) since the student was not enrolled for studies
at the institution.
b. In one (1) case, the student enrollment status was notified as being a withdrawal (W)
instead as being enrolled in nine (9) credits.
c. In one (1) case, the student enrollment status was notified as being enrolled in ten (10)
credits instead of being enrolled in thirteen (13) credits.
The enrollment status for these students was reported correctly in the subsequent Enrollment
Reports that were submitted.
Additionally, the enrollment reporting requirement applicable to institutions under the Pell Grant
and ED loan programs requires that institutions complete and return within 15 days the Enrollment
Reporting roster file (formerly the Student Status Confirmation Report (SSCR) placed in their
Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS. Regarding this, during
our evaluation of compliance with the Roster File return requirement, we were unable to verify
that the institution completed and returned any Enrollment Reports for the period from August
through December 2022.
Criteria
Dear College Letter (DCL) GEN-74-07, Subject: Changes to NSLDS Enrollment Reporting:
Program - Level Reporting and More Frequent Reporting, states that, under the authority of these
regulations, beginning July 1, 2014, we will request enrollment information from schools every 60
days and schools will be required to respond to those requests within 15 days of the date that we
send the electronic enrollment reporting roster to the school or to its designated third-party
servicer. Also, the section of the letter titled Program-Level Enrollment Reporting Required, states
that if the student is or was enrolled in more than one program, the student's enrollment
information must be reported for each of the programs. The NSLDS enrollment reporting rosters
include recipients of all Title IV loans and Federal Pell Grants. Including Pell Grant recipients will
allow the Department to meet the Congressional reporting requirements noted earlier. Note that
a student will only be included on the roster once, regardless of the number of different Title IV
programs from which the student received funding.
Page | 41
Universidad Teológica del Caribe, Inc.
Schedule of Findings and Questioned Costs (continued)
July 31, 2023
34 CFR 690.83 (b) (2) establishes that an institution shall submit, in accordance with deadline
dates established by the Secretary, through publication in the FEDERAL REGISTER, other
reports and information the Secretary requires and shall comply with the procedures the Secretary
finds necessary to ensure that the reports are correct.
34 CFR 685.309 (b) (1) and (2) establish that upon receipt of an enrollment report from the
Secretary, a school must update all information included in the report and return the report to the
Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) within the timeframe
prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the
Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date
the school discovers that - (i) A loan under title IV of the Act was made to or on behalf of a student
who was enrolled or accepted for enrollment at the school, and the student has ceased to be
enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period
for which the loan was intended; or (ii) A student who is enrolled at the school and who received
a loan under title IV of the Act has changed his or her permanent address.
Cause
The Institution's internal controls for tracking and reporting the enrollment changes failed to
identify the enrollment status changes performed manually by the Registrar's office personnel.
Effect
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. Failure to report will likely result in the school being out of compliance with the
regulatory requirements and possibly subject to sanctions. Also, failing to report completions at
all may cause borrowers to lose interest subsidy when they should not. And, because such
determinations are based on the student's enrollment (and completion) at the program level, it is
critically important that schools correctly and promptly report a student's completion at the
program level.
Questioned costs
None.
Identification as a Repeat Finding
A finding related to this compliance requirement was included in the prior year audit as Finding
No. 2021-004.
Recommendations
We recommend the Institution to determine what parts of the manual processes for this
requirement can be monitored electronically or using tools available in the USDE website with the
assistance of the IT consultant to help the Institution to comply with the deadline of the roster
reporting. Also, we recommend reinforcing the controls to report the enrollment status changes
of the participant students of the Pell and Direct Loan programs. In addition, a compliance officer
may assist in the reporting process.
Page | 42
Universidad Teológica del Caribe, Inc.
Schedule of Findings and Questioned Costs (continued)
July 31, 2023
Views of Responsible Officials
Refer to the Institutional comments included in the Corrective Action Plan.
Compliance requirement - Special tests and provisions – Enrollment Reporting
Institutional Comments on Findings and Recommendations:
The institution agrees with the auditor on this finding in that there were (3) three cases where the
enrollment status was not reported correctly. Although as was observed by the auditor, the
enrollment status for the three students in question were corrected in the next enrollment report
that was submitted.
During the audit period, the institution was unable to update, submit or complete in a timely
manner Enrollment reports for the period of July through December 2022. This was mainly due
to problems with the implementation of a new format for enrollment reporting through the NSLDS
Modernized Website.
The institution has on file, multiple inquiries to the NSLDS Customer Support Center in relation to
this issue.
The Department of Education also posted various Electronic Announcements updating and giving
continued guidance to institutions on this issue.
The auditors were provided with copies of all of ED’s posting and updates as related to this issue.
Nevertheless, during the subsequent months from January 2023 to June 2023 covered in this
audit period, the institution was able to complete and report the current enrollment status of
students to the NSLDS platform.
Actions Taken or Planned:
The matter as related to this finding has already been discussed with the Registrar who is
responsible for the completion and submission of the Enrollment Reports to the Department of
Education
To continue to improve on the reporting to student’s enrollment status, the institution would
continue to submit its Enrollment Reports monthly instead of every two months as schedule.
Status of Corrective Actions on Prior Findings:
The issue as related to this finding occurred in the past audit.
Federal programs: Federal Pell Grant Program; Federal Direct Loan Program
Finding Type: Significant Deficiency
Compliance requirement: Special tests and provisions - Return of Title IV Funds:
Condition and context.
In testing compliance with the return of Title IV requirement applicable after a student begins
attendance, we selected a sample of three (3) participants of the Title IV Student Financial
Assistance (SFA) programs who received $5,389.00 in SFA funds from a population of twelve
(12) students who withdrew, dropped out, or failed to attend to the Institution, who received
$21,167.00 in Title IV (SFA) funds. Our sample was a statistically valid sample.
We noted in two (2) cases of our sample that the Institution failed to determine that the student
withdrew within 14 days after the student's last date of attendance as determined by the Institution
from its attendance records.
Criteria
Withdrawals and the Return of Title IV Funds 2027-2022 of the Financial Student Aid Handbook
(Volume 5) establishes that if a student who began attendance and has not officially withdrawn
fails to earn a passing grade in at least one course offered over an entire period, the institution
must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the
institution can document that the student completed the period. Keep in mind that a grade of
"incomplete" is not considered a passing grade or successful completion.
Dear Colleague Letter GEN-04-03 (Revised November 2004) — states in item 2 that an institution
may have a grading policy as follows: F (Failing) Awarded to students who complete the course
but fail to achieve the course objectives. U (Unauthorized Incomplete) Awarded to students who
did not officially withdraw from the course, but who failed to participate in course activities through
the end of the period. It is used when, in the opinion of the instructor, completed assignments or
course activities or both were insufficient to make normal evaluation of academic performance
possible.
A student who did not officially withdraw and did not receive either a passing grade or an 'F' in at
least one course must be considered to have unofficially withdrawn. Important: Compliance audits
and program reviews may examine whether a school accurately assigns failing grades to students
if the school uses its grading policy to determine whether a student with failing grades has
unofficially withdrawn.
34 CFR 668.22 "Treatment of title IV funds when a student withdraws", section (a) General, (1)
states that when a recipient of title IV grant or loan assistance withdraws from an institution during
a payment period or period of enrollment in which the recipient began attendance, the institution
must determine the amount of title IV grant or loan assistance that the student earned as of the
student's withdrawal date in accordance with paragraph (e) of this section.
Page | 37
Universidad Teológica del Caribe, Inc.
Schedule of Findings and Questioned Costs (continued)
July 31, 2023
Also, in (b) "Withdrawal date for a student who withdraws from an institution that is required to
take attendance", section (1) states that for purposes of this section, for a student who ceases
attendance at an institution that is required to take attendance, including a student who does not
return from an approved leave of absence, as defined in paragraph (d) of this section, or a student
who takes a leave of absence that does not meet the requirements of paragraph (d) of this section,
the student's withdrawal date is the last date of academic attendance as determined by the
institution from its attendance records and section (2) states that an institution must document a
student's withdrawal date determined in accordance with paragraph (b)(1) of this section and
maintain the documentation as of the date of the institution's determination that the student
withdrew.34 CFR 668.22 (j), "Timeframe for the return of title IV funds", establishes that: (1) An
institution must return the amount of title IV funds for which it is responsible as soon as possible
but no later than 45 days after the date of the institution's determination that the student withdrew.
The timeframe for returning funds is further described in § 668.173(b); (2) For an institution that
is not required to take attendance, an institution must determine the withdrawal date for a student
who withdraws without providing notification to the institution no later than 30 days after the end
of the earlier of the - (i) Payment period or period of enrollment, as appropriate.
34 CFR 668.173 (b), "Timely return of title IV, HEA program funds", establishes that in accordance
with procedures established by the secretary, an institution returns unearned title IV, HEA
program funds timely if - (1) the institution deposits or transfers the funds into the bank account it
maintains under § 668.163 no later than 45 days after the date it determines that the student
withdrew.
Dear Colleague Letter GEN-04-03 (Revised November 2004) - Subject: Return of Title IV Aid
states that Institutions are expected to have procedures to determine when a student's absence
is a withdrawal. Institutions that are required to take attendance are expected to have a procedure
in place for routinely monitoring attendance records to determine in a timely manner when a
student withdraws. Except in unusual instances, at an institution that is required to take
attendance, they would expect that the date of the institution's determination that the student
withdrew would be no later than 14 days after the student's withdrawal date - the last date of
academic attendance as determined by the institution from its attendance records (34 CFR
668.22(b)(1)).
Cause
The Institution's internal controls for tracking and calculating the return of title IV funds of the
students who withdrew, drop out or stopped attending the Institution failed to identify and process
these cases as required and on a timely basis.
Effect
The failure to correct these deficiencies which have been cited in prior audits may result in the
Institution being referred to the Department's Administrative Actions and Appeals Service Group
(AAASG) for possible adverse action. Such action may include a fine, or the limitation,
suspension, or termination of the eligibility of the Institution. Such action may also include the
revocation of the institution's program participation agreement (if provisional), or, if the Institution
has an application pending for renewal of its certification, denial of that application.
Page | 38
Universidad Teológica del Caribe, Inc.
Schedule of Findings and Questioned Costs (continued)
July 31, 2023
Questioned costs
Less than $25,000, if any.
Identification as a Repeat Finding
A finding related to this compliance requirement was included in the prior year audit as Finding
No. 2021-003.
Recommendations
We recommend the Institution to improve its procedures to ascertain that the return of Title IV
funds requirements is properly followed and unearned funds are properly calculated and returned
timely to the USDE. Also, the Institution should consider creating a position of compliance officer.
Educational institutions must meet and observe a wide variety of guidelines and regulations set
by both government agencies and nongovernmental associations to receive financial support and
maintain accreditation. A school's compliance officer spreads awareness of policies, coordinates
programs to promote the observation of guidelines and reports to a top-level administrator.
Views of Responsible Officials
Refer to the Institutional comments included in the Corrective Action Plan.
Institutional Comments on Findings and Recommendations:
Compliance Requirements – Applicable After a Student Begins Attendance:
The institution agrees with the auditors on this finding in which there were two (2) cases where
the auditors noted that the institution failed to determine that the students withdrew within fourteen
(14) days after the student’s last day of attendance.
In one (1) of the two (2) cases the Date of Determination was twenty-two (22) days after the Last
Day of Attendance and in the second case, the Date of Determination was Three (3) days after
the Last Day of Attendance.
All funds due to the Department, (for the first case $682.00 of Unsub. Direct Loan funds and in
the second case $974.22 of Federal Pell Grant funds), were returned within the forty-five (45)
days required timeframe as of the Date of Determination of each case.
This process was evidenced to the auditors for their records.
Actions Taken or Planned:
The institution is fully aware of the Return of Title IV funds (R2T4) reporting requirements and
deadlines.
The issue related to this finding was identified as a lack in some Faculty notifying student
absences within the fourteen (14) day timeframe to process an R2T4 in a timely manner as
required.
Although this issue was already discussed with them by the Dean of Academic Affairs, an
additional follow up meeting would be held to remind them of the importance in monitoring student
Page | 39
Universidad Teológica del Caribe, Inc.
Schedule of Findings and Questioned Costs (continued)
July 31, 2023
attendance and notifying student absences to the Registrar office within the required timeframes
to fully comply with the R2T4 reporting requirements.
Status of Corrective Actions on Prior Findings:
The issue as related to this finding occurred in the past audit.
Federal programs: Federal Pell Grant Program; Federal Direct Loan Program
Compliance requirement: Special tests and provisions - Enrollment reporting
Condition and context.
During our enrollment reporting test, for a statistically valid sample of ten (10) students from a
population of thirty-five (35) records that had a reduction or increase in attendance levels,
graduated, withdrew, dropped out, or enrolled but never attended during the audit period, we
noted the following deficiencies:
In three (3) cases, we noted that the Institution did not report the correct enrollment status for
these students.
a. In one (1) case, the student enrollment status was notified as being enrolled in six (6)
credits instead of being a withdrawal (W) since the student was not enrolled for studies
at the institution.
b. In one (1) case, the student enrollment status was notified as being a withdrawal (W)
instead as being enrolled in nine (9) credits.
c. In one (1) case, the student enrollment status was notified as being enrolled in ten (10)
credits instead of being enrolled in thirteen (13) credits.
The enrollment status for these students was reported correctly in the subsequent Enrollment
Reports that were submitted.
Additionally, the enrollment reporting requirement applicable to institutions under the Pell Grant
and ED loan programs requires that institutions complete and return within 15 days the Enrollment
Reporting roster file (formerly the Student Status Confirmation Report (SSCR) placed in their
Student Aid Internet Gateway (SAIG) mailboxes sent by ED via NSLDS. Regarding this, during
our evaluation of compliance with the Roster File return requirement, we were unable to verify
that the institution completed and returned any Enrollment Reports for the period from August
through December 2022.
Criteria
Dear College Letter (DCL) GEN-74-07, Subject: Changes to NSLDS Enrollment Reporting:
Program - Level Reporting and More Frequent Reporting, states that, under the authority of these
regulations, beginning July 1, 2014, we will request enrollment information from schools every 60
days and schools will be required to respond to those requests within 15 days of the date that we
send the electronic enrollment reporting roster to the school or to its designated third-party
servicer. Also, the section of the letter titled Program-Level Enrollment Reporting Required, states
that if the student is or was enrolled in more than one program, the student's enrollment
information must be reported for each of the programs. The NSLDS enrollment reporting rosters
include recipients of all Title IV loans and Federal Pell Grants. Including Pell Grant recipients will
allow the Department to meet the Congressional reporting requirements noted earlier. Note that
a student will only be included on the roster once, regardless of the number of different Title IV
programs from which the student received funding.
Page | 41
Universidad Teológica del Caribe, Inc.
Schedule of Findings and Questioned Costs (continued)
July 31, 2023
34 CFR 690.83 (b) (2) establishes that an institution shall submit, in accordance with deadline
dates established by the Secretary, through publication in the FEDERAL REGISTER, other
reports and information the Secretary requires and shall comply with the procedures the Secretary
finds necessary to ensure that the reports are correct.
34 CFR 685.309 (b) (1) and (2) establish that upon receipt of an enrollment report from the
Secretary, a school must update all information included in the report and return the report to the
Secretary - (i) In the manner and format prescribed by the Secretary; and (ii) within the timeframe
prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the
Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date
the school discovers that - (i) A loan under title IV of the Act was made to or on behalf of a student
who was enrolled or accepted for enrollment at the school, and the student has ceased to be
enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period
for which the loan was intended; or (ii) A student who is enrolled at the school and who received
a loan under title IV of the Act has changed his or her permanent address.
Cause
The Institution's internal controls for tracking and reporting the enrollment changes failed to
identify the enrollment status changes performed manually by the Registrar's office personnel.
Effect
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. Failure to report will likely result in the school being out of compliance with the
regulatory requirements and possibly subject to sanctions. Also, failing to report completions at
all may cause borrowers to lose interest subsidy when they should not. And, because such
determinations are based on the student's enrollment (and completion) at the program level, it is
critically important that schools correctly and promptly report a student's completion at the
program level.
Questioned costs
None.
Identification as a Repeat Finding
A finding related to this compliance requirement was included in the prior year audit as Finding
No. 2021-004.
Recommendations
We recommend the Institution to determine what parts of the manual processes for this
requirement can be monitored electronically or using tools available in the USDE website with the
assistance of the IT consultant to help the Institution to comply with the deadline of the roster
reporting. Also, we recommend reinforcing the controls to report the enrollment status changes
of the participant students of the Pell and Direct Loan programs. In addition, a compliance officer
may assist in the reporting process.
Page | 42
Universidad Teológica del Caribe, Inc.
Schedule of Findings and Questioned Costs (continued)
July 31, 2023
Views of Responsible Officials
Refer to the Institutional comments included in the Corrective Action Plan.
Compliance requirement - Special tests and provisions – Enrollment Reporting
Institutional Comments on Findings and Recommendations:
The institution agrees with the auditor on this finding in that there were (3) three cases where the
enrollment status was not reported correctly. Although as was observed by the auditor, the
enrollment status for the three students in question were corrected in the next enrollment report
that was submitted.
During the audit period, the institution was unable to update, submit or complete in a timely
manner Enrollment reports for the period of July through December 2022. This was mainly due
to problems with the implementation of a new format for enrollment reporting through the NSLDS
Modernized Website.
The institution has on file, multiple inquiries to the NSLDS Customer Support Center in relation to
this issue.
The Department of Education also posted various Electronic Announcements updating and giving
continued guidance to institutions on this issue.
The auditors were provided with copies of all of ED’s posting and updates as related to this issue.
Nevertheless, during the subsequent months from January 2023 to June 2023 covered in this
audit period, the institution was able to complete and report the current enrollment status of
students to the NSLDS platform.
Actions Taken or Planned:
The matter as related to this finding has already been discussed with the Registrar who is
responsible for the completion and submission of the Enrollment Reports to the Department of
Education
To continue to improve on the reporting to student’s enrollment status, the institution would
continue to submit its Enrollment Reports monthly instead of every two months as schedule.
Status of Corrective Actions on Prior Findings:
The issue as related to this finding occurred in the past audit.