Audit 31533

FY End
2022-06-30
Total Expended
$349.21M
Findings
4
Programs
45
Year: 2022 Accepted: 2023-03-07
Auditor: Galindez LLC

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
34866 2022-001 - Yes N
34867 2022-002 - Yes N
611308 2022-001 - Yes N
611309 2022-002 - Yes N

Programs

ALN Program Spent Major Findings
84.063 Federal Pell Grant Program $95.49M Yes 1
84.268 Federal Direct Student Loans $65.16M Yes 1
84.007 Federal Supplemental Educational Opportunity Grants $3.28M Yes 0
84.031 Higher Education_institutional Aid $2.76M - 0
84.047 Trio_upward Bound $2.18M Yes 0
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $1.56M - 0
84.033 Federal Work-Study Program $1.47M Yes 0
16.575 Crime Victim Assistance $1.19M - 0
84.066 Trio_educational Opportunity Centers $1.04M Yes 0
59.037 Small Business Development Centers $790,663 - 0
84.425 Education Stabilization Fund $684,363 Yes 0
84.002 Adult Education - Basic Grants to States $639,872 - 0
47.076 Education and Human Resources $609,356 - 0
12.630 Basic, Applied, and Advanced Research in Science and Engineering $580,948 - 0
84.042 Trio_student Support Services $563,830 Yes 0
84.149 Migrant Education_college Assistance Migrant Program $474,469 - 0
84.141 Migrant Education_high School Equivalency Program $394,111 - 0
84.044 Trio_talent Search $309,574 Yes 0
84.120 Minority Science and Engineering Improvement $293,640 - 0
84.335 Child Care Access Means Parents in School $274,237 - 0
84.217 Trio_mcnair Post-Baccalaureate Achievement $241,664 Yes 0
81.123 National Nuclear Security Administration (nnsa) Minority Serving Institutions (msi) Program $207,498 - 0
93.859 Biomedical Research and Research Training $200,190 - 0
10.223 Hispanic Serving Institutions Education Grants $126,869 - 0
47.050 Geosciences $123,781 - 0
84.938 Disaster Recovery Assistance for Education $113,602 - 0
16.746 Capital Case Litigation Initiative $83,773 - 0
17.259 Wia Youth Activities $63,252 - 0
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $51,401 - 0
93.586 State Court Improvement Program $44,760 - 0
21.019 Coronavirus Relief Fund $42,673 - 0
15.634 State Wildlife Grants $40,261 - 0
15.657 Endangered Species Conservation ? Recovery Implementation Funds $34,630 - 0
43.008 Education $32,994 - 0
16.029 Office on Violence Against Women Special Projects $31,212 - 0
45.312 National Leadership Grants $26,931 - 0
10.310 Agriculture and Food Research Initiative (afri) $25,691 - 0
20.109 Air Transportation Centers of Excellence $23,936 - 0
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $16,912 Yes 0
10.675 Urban and Community Forestry Program $15,891 - 0
93.124 Nurse Anesthetist Traineeships $15,134 - 0
59.061 State Trade and Export Promotion Pilot Grant Program $9,968 - 0
16.034 Coronavirus Emergency Supplemental Funding Program $8,934 - 0
47.074 Biological Sciences $4,003 - 0
59.058 Federal and State Technology Partnership Program $3,676 - 0

Contacts

Name Title Type
PMELJCUDNL17 Orlando Gonzalez Auditee
7877586260 Rafael Nieves Auditor
No contacts on file

Notes to SEFA

Title: Assistance Listing (AL) Number Accounting Policies: Expenditures reported in the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. The University has elected not to use the 10 percent de minimis indirect cost rate, as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The AL numbers included in the Schedule are determined based on the program name, review of grant contract information and the OMBs Assistance Listing Number.
Title: Major Federal Programs Accounting Policies: Expenditures reported in the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. The University has elected not to use the 10 percent de minimis indirect cost rate, as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Major programs are identified in the Summary of Auditors Results Section in the Schedule of Findings and Questioned Costs. Federal programs are presented by federal agency.
Title: Accounting Policies for Loans and Loan Guarantees Accounting Policies: Expenditures reported in the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. The University has elected not to use the 10 percent de minimis indirect cost rate, as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The University participates in the Federal Direct Student Loans (Direct Loans) program of the U.S. Department of Education (USDE). Under the Direct Loans program, the University is responsible only for certain administrative duties, accordingly, the disbursements under the program and the outstanding loan balances are excluded from the consolidated financial statements of the University. However, Direct Loans are considered a component of the student financial assistance programs of the University, as such, new loans processed during the year ended June 30, 2022 amounting to $65,160,355 were included in the Schedule. Federal expenditures for Direct Loans are determined when loans are made to the students, accordingly, the balance of Direct Loans from previous years is not considered federal expenditures of the current year. Direct Loans are made by the Secretary of Education. The Students Aid Reports (SAR) or Institutional Student Information Record (ISIR), along with other information, is used by the University to originate a students loan.
Title: Noncash Program Accounting Policies: Expenditures reported in the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures may or may not be allowable or may be limited as to reimbursement. The University has elected not to use the 10 percent de minimis indirect cost rate, as allowed under the Uniform Guidance. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The consolidated financial statements of the University include the following notes payable to the USDE, which are not included in the Schedule: Advances under a credit agreement with the U.S. Department of Education, payable in semiannual installments of $95,816, including interest, through November 2024, with interest at 5.50% and secured by a mortgage note on certain building in the San German campus $523,382. Advances under a credit agreement with the U.S. Department of Education, payable in semiannual installments of $14,304, including interest, through January 2030, with interest at 5.50% and secured by a mortgage note on certain building in the Fajardo campus $183,156. Advances under a credit agreement with the U.S. Department of Education, payable in semiannual installments of $60,569, including interest, through April 2030, with interest at 5.50% and secured by a mortgage note on certain property in the San German campus $775,566.

Finding Details

Finding No. 2022?001 - Special Tests and Provisions - Return of Title IV Funds Federal Program Name Student Financial Assistance Programs Cluster - Federal Pell Grant Program (PELL), AL No. 84.063 Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria According to 34 CFR 668.22(j)(2) for an institution that is not required to take attendance, it must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the: (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e)(5) of this section; (ii) Academic year in which the student withdrew; or (iii) Educational program from which the student withdrew. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all nine (9) students from the selected campuses that failed to earn a passing grade, for a total of sixty-nine (69) students, and noted that for one (1) student, the determination of withdrawal was performed after the required 30 days, as follows: See Schedule of Findings and Questioned Costs for chart/table Cause The San German campus reinstated the student after a withdrawal was processed. At the end of the term, the professor reported an administrative withdrawal (UW) for the student, however, such administrative withdrawal was not properly processed due to the existence of the previous return of Title IV funds record on system. As a result, the return of Title IV funds was not processed on a timely manner. Effect As a result of this instance of noncompliance, the USDE may issue warnings and/or impose penalties on the University. Also, the incorrect return of Title IV funds could limit the students? future eligibility to Title IV funds. Questioned Costs None. Context Of the 2,539 withdrawals from the selected campuses for the year ended June 30, 2022, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all nine (9) students from the selected campuses that failed to earn a passing grade, for a total of sixty-nine (69) students, and noted one (1) instance of noncompliance. Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Pell funds: See Schedule of Findings and Questioned Costs for chart/table Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Direct Loans: See Schedule of Findings and Questioned Costs for chart/table Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2021-002). Recommendation The University San German Campus? management should reinforce its procedures to ensure the identification and timely resolution of instances in which students withdrew without providing notification to the University. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 67-69.
Finding No. 2022?002 - Special Tests and Provisions ? Enrollment Reporting Federal Program Name Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of 40 students who graduated and/or withdrew during 2022, we noted one (1) student for which the University did not report to the National Student Loan Data System (NSLDS) the student status change within the required 60 days? period. Cause Late submissions resulted from the length of time required by the University?s administrative procedures for graduated students and/or from discrepancies identified by the National Student Clearinghouse (NSC), in the students? information. Effect As a result of this condition, the USDE was prevented the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Costs None. Context Of the 5,330 status changes from the selected campuses for 2022, we selected 40 students for testing and noted one (1) instance in which the University did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2021-003). Recommendation The University should enhance its control procedures to ensure all enrollment status changes, including graduate students, are timely and accurately reported to NSDLS. Management should reassess the time-frame in which the University submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting time-frame. The University should enhance both electronic and manual procedures to ensure student loan borrower enrollment status changes are timely and accurately reported to NSLDS. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 67-69.
Finding No. 2022?001 - Special Tests and Provisions - Return of Title IV Funds Federal Program Name Student Financial Assistance Programs Cluster - Federal Pell Grant Program (PELL), AL No. 84.063 Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Criteria According to 34 CFR 668.22(j)(2) for an institution that is not required to take attendance, it must determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the: (i) Payment period or period of enrollment, as appropriate, in accordance with paragraph (e)(5) of this section; (ii) Academic year in which the student withdrew; or (iii) Educational program from which the student withdrew. Condition In testing compliance with the return of Title IV funds requirements, we made a selection of sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all nine (9) students from the selected campuses that failed to earn a passing grade, for a total of sixty-nine (69) students, and noted that for one (1) student, the determination of withdrawal was performed after the required 30 days, as follows: See Schedule of Findings and Questioned Costs for chart/table Cause The San German campus reinstated the student after a withdrawal was processed. At the end of the term, the professor reported an administrative withdrawal (UW) for the student, however, such administrative withdrawal was not properly processed due to the existence of the previous return of Title IV funds record on system. As a result, the return of Title IV funds was not processed on a timely manner. Effect As a result of this instance of noncompliance, the USDE may issue warnings and/or impose penalties on the University. Also, the incorrect return of Title IV funds could limit the students? future eligibility to Title IV funds. Questioned Costs None. Context Of the 2,539 withdrawals from the selected campuses for the year ended June 30, 2022, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all nine (9) students from the selected campuses that failed to earn a passing grade, for a total of sixty-nine (69) students, and noted one (1) instance of noncompliance. Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Pell funds: See Schedule of Findings and Questioned Costs for chart/table Following is a description of the sample that included the finding identified and the population from which the sample was drawn for students that received Direct Loans: See Schedule of Findings and Questioned Costs for chart/table Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2021-002). Recommendation The University San German Campus? management should reinforce its procedures to ensure the identification and timely resolution of instances in which students withdrew without providing notification to the University. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 67-69.
Finding No. 2022?002 - Special Tests and Provisions ? Enrollment Reporting Federal Program Name Federal Direct Student Loan Program (DL) CFDA No. 84.268 Name of Federal Agency U.S. Department of Education Pass-through Entity N/A Criteria 34 CFR 685.309 (b)(2) states that unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that; a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition As part of our testing of 40 students who graduated and/or withdrew during 2022, we noted one (1) student for which the University did not report to the National Student Loan Data System (NSLDS) the student status change within the required 60 days? period. Cause Late submissions resulted from the length of time required by the University?s administrative procedures for graduated students and/or from discrepancies identified by the National Student Clearinghouse (NSC), in the students? information. Effect As a result of this condition, the USDE was prevented the use of accurate reporting data, which is critical for the effective administration of the Direct Loan Program and for USDE budgetary policy analysis. Questioned Costs None. Context Of the 5,330 status changes from the selected campuses for 2022, we selected 40 students for testing and noted one (1) instance in which the University did not comply with the enrollment reporting requirements. Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2021-003). Recommendation The University should enhance its control procedures to ensure all enrollment status changes, including graduate students, are timely and accurately reported to NSDLS. Management should reassess the time-frame in which the University submits the information to the NSC and reinforce its monitoring of NSC to ensure they comply with the agreed upon reporting time-frame. The University should enhance both electronic and manual procedures to ensure student loan borrower enrollment status changes are timely and accurately reported to NSLDS. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Refer to the corrective action plan on pages 67-69.