Title: BASIS PRESENTATION
Accounting Policies: Expenditures included in the Schedule, except for the “Disaster Grants – Public Assistance” (ALN 97.036), are reported on the accrual basis of accounting, which is further explained in Note 1 to the accompanying financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, where in certain types of expenditures are not allowable or limited as to reimbursements. The related amounts in the Schedule agree with the amounts reported in the accompanying financial statements.
Expenditures for the “Disaster Grants – Public Assistance” are recognized in the period when: (1) the Federal Emergency Management Agency (FEMA) has approved the Project Worksheet (PW), and (2) eligible expenditures are incurred. This results in presenting eligible expenditures incurred in prior years in the current year SEFA because the PW was approved in subsequent years, except as explained in Note 11
De Minimis Rate Used: N
Rate Explanation: The Corporation has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance
The accompanying Schedule of Expenditures of Federal Awards (“the Schedule” or “SEFA”) includes the federal grant activity of the Corporation under programs of the federal government for the year ended June 30, 2024. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the Corporation, it is not intended to and does not present the financial position, changes in net assets or cash flows of the Corporation.
Title: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES
Accounting Policies: Expenditures included in the Schedule, except for the “Disaster Grants – Public Assistance” (ALN 97.036), are reported on the accrual basis of accounting, which is further explained in Note 1 to the accompanying financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, where in certain types of expenditures are not allowable or limited as to reimbursements. The related amounts in the Schedule agree with the amounts reported in the accompanying financial statements.
Expenditures for the “Disaster Grants – Public Assistance” are recognized in the period when: (1) the Federal Emergency Management Agency (FEMA) has approved the Project Worksheet (PW), and (2) eligible expenditures are incurred. This results in presenting eligible expenditures incurred in prior years in the current year SEFA because the PW was approved in subsequent years, except as explained in Note 11
De Minimis Rate Used: N
Rate Explanation: The Corporation has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance
Expenditures included in the Schedule, except for the “Disaster Grants – Public Assistance” (ALN 97.036), are reported on the accrual basis of accounting, which is further explained in Note 1 to the accompanying financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, where in certain types of expenditures are not allowable or limited as to reimbursements. The related amounts in the Schedule agree with the amounts reported in the accompanying financial statements.
Expenditures for the “Disaster Grants – Public Assistance” are recognized in the period when: (1) the Federal Emergency Management Agency (FEMA) has approved the Project Worksheet (PW), and (2) eligible expenditures are incurred. This results in presenting eligible expenditures incurred in prior years in the current year SEFA because the PW was approved in subsequent years, except as explained in Note 11.
Title: RELATION TO FEDERAL FINANCIAL REPORTS
Accounting Policies: Expenditures included in the Schedule, except for the “Disaster Grants – Public Assistance” (ALN 97.036), are reported on the accrual basis of accounting, which is further explained in Note 1 to the accompanying financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, where in certain types of expenditures are not allowable or limited as to reimbursements. The related amounts in the Schedule agree with the amounts reported in the accompanying financial statements.
Expenditures for the “Disaster Grants – Public Assistance” are recognized in the period when: (1) the Federal Emergency Management Agency (FEMA) has approved the Project Worksheet (PW), and (2) eligible expenditures are incurred. This results in presenting eligible expenditures incurred in prior years in the current year SEFA because the PW was approved in subsequent years, except as explained in Note 11
De Minimis Rate Used: N
Rate Explanation: The Corporation has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance
The regulations and guidelines governing the preparation of federal financial reports vary by federal agency and among programs administered by the same agency. Accordingly, the amounts reported in the federal financial reports do not necessarily agree with the amounts reported in the accompanying schedule, which is prepared on the basis of accounting explained in Note 1.
Set forth in 200.327 Financial reporting and 200.328 Monitoring and reporting program performance, if a Federal awarding agency requires reporting on an accrual basis from a recipient that maintains its records on other than an accrual basis, the recipient must not be required to establish an accrual accounting system. This recipient may develop accrual data for its reports on the basis of an analysis of the documentation on hand. The Corporation prepares the federal financial reports on accrual basis of accounting primarily based on information from the internal accounting records of the Corporation.
Title: RELATION TO FINANCIAL STATEMENTS
Accounting Policies: Expenditures included in the Schedule, except for the “Disaster Grants – Public Assistance” (ALN 97.036), are reported on the accrual basis of accounting, which is further explained in Note 1 to the accompanying financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, where in certain types of expenditures are not allowable or limited as to reimbursements. The related amounts in the Schedule agree with the amounts reported in the accompanying financial statements.
Expenditures for the “Disaster Grants – Public Assistance” are recognized in the period when: (1) the Federal Emergency Management Agency (FEMA) has approved the Project Worksheet (PW), and (2) eligible expenditures are incurred. This results in presenting eligible expenditures incurred in prior years in the current year SEFA because the PW was approved in subsequent years, except as explained in Note 11
De Minimis Rate Used: N
Rate Explanation: The Corporation has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance
Federal awards revenues and expenses are reported in the Corporation's Statement Activities and Changes in Net Position, in accordance with standards issued by the Government Accounting Standards Board (GASB) No. 35. Because the Schedule of Expenditures of Federal Awards presents only federal activities of the Corporation, it is not intended to and does not present the financial position, assets, liabilities, net position, revenues, expenses, changes in net position, and cash flows, as a whole.
Title: CLUSTER PROGRAMS
Accounting Policies: Expenditures included in the Schedule, except for the “Disaster Grants – Public Assistance” (ALN 97.036), are reported on the accrual basis of accounting, which is further explained in Note 1 to the accompanying financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, where in certain types of expenditures are not allowable or limited as to reimbursements. The related amounts in the Schedule agree with the amounts reported in the accompanying financial statements.
Expenditures for the “Disaster Grants – Public Assistance” are recognized in the period when: (1) the Federal Emergency Management Agency (FEMA) has approved the Project Worksheet (PW), and (2) eligible expenditures are incurred. This results in presenting eligible expenditures incurred in prior years in the current year SEFA because the PW was approved in subsequent years, except as explained in Note 11
De Minimis Rate Used: N
Rate Explanation: The Corporation has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance
2 CFR 200.17 defines a cluster of programs as a grouping of closely related programs that share common compliance requirements. According to this definition, Federal Student Financial Assistance Programs were deemed to be a cluster of programs and were tested accordingly.
Title: LOAN PROGRAM
Accounting Policies: Expenditures included in the Schedule, except for the “Disaster Grants – Public Assistance” (ALN 97.036), are reported on the accrual basis of accounting, which is further explained in Note 1 to the accompanying financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, where in certain types of expenditures are not allowable or limited as to reimbursements. The related amounts in the Schedule agree with the amounts reported in the accompanying financial statements.
Expenditures for the “Disaster Grants – Public Assistance” are recognized in the period when: (1) the Federal Emergency Management Agency (FEMA) has approved the Project Worksheet (PW), and (2) eligible expenditures are incurred. This results in presenting eligible expenditures incurred in prior years in the current year SEFA because the PW was approved in subsequent years, except as explained in Note 11
De Minimis Rate Used: N
Rate Explanation: The Corporation has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance
William D. Ford Federal Direct Loan - The Corporation is responsible only for the performance of certain administrative duties with respect to the William D. Ford Federal Direct Loan. Accordingly, balances and transactions relating to this program are not included in the Corporation's basic financial statements. Therefore, it is not practical to determine the balance of Loans outstanding to students and former students of the Corporation at June 30, 2024.
Federally guaranteed loans issued to students of the Corporation during the year ended June 30, 2024, are summarized as follows:
Federal Assistance Listing Number
2024
William D. Ford Federal Direct Loan Program 84.268 $ 252,296
Title: DISTINCTION BETWEEN TYPE A AND TYPE B PROGRAMS
Accounting Policies: Expenditures included in the Schedule, except for the “Disaster Grants – Public Assistance” (ALN 97.036), are reported on the accrual basis of accounting, which is further explained in Note 1 to the accompanying financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, where in certain types of expenditures are not allowable or limited as to reimbursements. The related amounts in the Schedule agree with the amounts reported in the accompanying financial statements.
Expenditures for the “Disaster Grants – Public Assistance” are recognized in the period when: (1) the Federal Emergency Management Agency (FEMA) has approved the Project Worksheet (PW), and (2) eligible expenditures are incurred. This results in presenting eligible expenditures incurred in prior years in the current year SEFA because the PW was approved in subsequent years, except as explained in Note 11
De Minimis Rate Used: N
Rate Explanation: The Corporation has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance
The dollar threshold for Type A and Type B programs amounted to $750,000.
Title: MATCHING COSTS
Accounting Policies: Expenditures included in the Schedule, except for the “Disaster Grants – Public Assistance” (ALN 97.036), are reported on the accrual basis of accounting, which is further explained in Note 1 to the accompanying financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, where in certain types of expenditures are not allowable or limited as to reimbursements. The related amounts in the Schedule agree with the amounts reported in the accompanying financial statements.
Expenditures for the “Disaster Grants – Public Assistance” are recognized in the period when: (1) the Federal Emergency Management Agency (FEMA) has approved the Project Worksheet (PW), and (2) eligible expenditures are incurred. This results in presenting eligible expenditures incurred in prior years in the current year SEFA because the PW was approved in subsequent years, except as explained in Note 11
De Minimis Rate Used: N
Rate Explanation: The Corporation has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance
Matching costs, such as the non-federal share of certain program costs, are not included in the accompanying Schedule.
Title: INDIRECT COST
Accounting Policies: Expenditures included in the Schedule, except for the “Disaster Grants – Public Assistance” (ALN 97.036), are reported on the accrual basis of accounting, which is further explained in Note 1 to the accompanying financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, where in certain types of expenditures are not allowable or limited as to reimbursements. The related amounts in the Schedule agree with the amounts reported in the accompanying financial statements.
Expenditures for the “Disaster Grants – Public Assistance” are recognized in the period when: (1) the Federal Emergency Management Agency (FEMA) has approved the Project Worksheet (PW), and (2) eligible expenditures are incurred. This results in presenting eligible expenditures incurred in prior years in the current year SEFA because the PW was approved in subsequent years, except as explained in Note 11
De Minimis Rate Used: N
Rate Explanation: The Corporation has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance
The Corporation has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance.
Title: PASS-THROUGH
Accounting Policies: Expenditures included in the Schedule, except for the “Disaster Grants – Public Assistance” (ALN 97.036), are reported on the accrual basis of accounting, which is further explained in Note 1 to the accompanying financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, where in certain types of expenditures are not allowable or limited as to reimbursements. The related amounts in the Schedule agree with the amounts reported in the accompanying financial statements.
Expenditures for the “Disaster Grants – Public Assistance” are recognized in the period when: (1) the Federal Emergency Management Agency (FEMA) has approved the Project Worksheet (PW), and (2) eligible expenditures are incurred. This results in presenting eligible expenditures incurred in prior years in the current year SEFA because the PW was approved in subsequent years, except as explained in Note 11
De Minimis Rate Used: N
Rate Explanation: The Corporation has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance
No federal grant dollar has been passed through to sub-recipient.
Title: CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS
Accounting Policies: Expenditures included in the Schedule, except for the “Disaster Grants – Public Assistance” (ALN 97.036), are reported on the accrual basis of accounting, which is further explained in Note 1 to the accompanying financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, where in certain types of expenditures are not allowable or limited as to reimbursements. The related amounts in the Schedule agree with the amounts reported in the accompanying financial statements.
Expenditures for the “Disaster Grants – Public Assistance” are recognized in the period when: (1) the Federal Emergency Management Agency (FEMA) has approved the Project Worksheet (PW), and (2) eligible expenditures are incurred. This results in presenting eligible expenditures incurred in prior years in the current year SEFA because the PW was approved in subsequent years, except as explained in Note 11
De Minimis Rate Used: N
Rate Explanation: The Corporation has not elected to use the 10% de minimis indirect cost rate allowed under the Uniform Guidance
During the fiscal year ended June 30, 2021, the governor of Puerto Rico assigned to the Corporation an allocation of the Coronavirus State and Local Fiscal Recovery Fund (“SLFRF”), from the Section 9901 of the American Rescue Plan Act (“ARPA”). The Corporation was granted funds of this award by a local government pass-through entity. The amounts received and used were recorded in the corresponding financial statements for 2022, 2023 and 2024. The expenditures during each fiscal year were as follows:
As of June 30, Amount
2022 $ 277,315
2023 484,233
2024 1,582,015
Total $ 2,343,563
The expenditures under this pass-through grant for 2022 and 2023 were not reported in the corresponding SEFA. The cause of the omission was an oversight by the Corporation in realizing the source of the funds and the reporting impact. Notwithstanding, the local pass-through entity exercised monitoring activities on the Corporation by establishing reporting and other requirements between them for the use and report of the funds. Such requirements were satisfied at the corresponding time.
This condition was the subject of a consultation with an officer at the U.S. Department of the Treasury, the federal grantor agency. The recommendation received was to include and properly disclose the expenditures of 2022 and 2023 in the SEFA for 2024.