Finding Number: 2025-002 Federal Program: Student Financial Assistance (SFA) Cluster - Various ALN Control Requirement - Return of Title IV Funds Management’s Response The University of Puerto Rico concurs with this finding. Institutional units have identified opportunities for improvement in intern...
Finding Number: 2025-002 Federal Program: Student Financial Assistance (SFA) Cluster - Various ALN Control Requirement - Return of Title IV Funds Management’s Response The University of Puerto Rico concurs with this finding. Institutional units have identified opportunities for improvement in internal controls related to the timely return of Title IV funds and have implemented, or are in the process of implementing, corrective measures to ensure compliance with the regulatory timeframe of 45 days. The Cayey unit identified that the delay in the return of Title IV funds was related to an unintentional administrative error in the handling and filing of R2T4 documentation, within a context of operational transition and temporary staffing limitations. As a corrective action, the Fiscal Office will strengthen periodic reviews of total withdrawal reports generated in the NEXT system, ensure proper classification and monitoring of R2T4 cases, and provide continuous follow-up until funds are effectively returned within the 45 days regulatory timeframe. As a control mechanism, direct oversight of the R2T4 process by the Finance Director has been established, including recurring reviews of total withdrawal reports and reconciliation of these reports with refund vouchers, in order to ensure that all cases are processed and returned in a timely manner. The Humacao unit acknowledged that the cases identified by the auditors were related to specific circumstances, including system errors, technical limitations, and operational workload associated with the implementation of the shared services model. As a corrective measure, the unit implemented changes to the total withdrawal request form and process to ensure coordinated handling between the Office of Financial Aid and the Fiscal Office, allowing for early identification of cases subject to R2T4. Additionally, the Fiscal Office will review total withdrawal reports generated by the NEXT system on a recurring basis, perform R2T4 calculations timely, and coordinate with the Office of Finance to process returns within the regulatory timeframe. Oversight of the process has been strengthened through the designation of responsible personnel and continuous monitoring of active cases through completion. The Carolina unit identified that delays in the return of Title IV funds were due to discrepancies in attendance reports that were subsequently amended. As a corrective action, the Office of Financial Aid will formally notify the Fiscal Office of any corrections or amendments to attendance reports to ensure that R2T4 cases are identified timely. In addition, the use of “Never Attended” reports has been reinforced at the conclusion of the census period and upon completion of the grade submission period. Once the R2T4 calculation is completed in the COD system and a return is determined, the refund process will be initiated immediately, accompanied by continuous follow-up and the scheduling of key dates to ensure compliance with the 45 days regulatory requirement. The Central Administration Finance Office will conduct a meeting with Finance Directors, Financial Aid Directors, the Office of the Registrar, and Fiscal Directors to discuss this finding and establish a uniform procedure to address the following scenarios: • Students who request a total withdrawal. • Students who stopped attending. • Students who never attended. Additionally, a control mechanism will be implemented through the SharePoint platform, whereby each Fiscal Director will certify that system reviews have been performed for cases approaching the 45 days regulatory deadline. This control will be performed on a bi-weekly basis and will allow for timely monitoring of active cases, ensuring proper compliance with the required return of funds. For cases related to grade-based census determinations, which are processed once faculty submit grades in the system, an additional control mechanism will be established. Specifically, the SharePoint tool will be used for Fiscal Directors to document the academic calendar deadlines for grade submission. Furthermore, Fiscal Directors will schedule Outlook calendar events with these deadlines, including the Director of Financial Aid and the Office of the Registrar, and will establish automated reminders to ensure timely follow-up. These procedures will be documented and incorporated into the internal control manual applicable to the R2T4 process. Responsible Person or Office: Central Administration Finance Office and the finance offices of each of the eleven (11) institutional units. Implementation Timeline: 2026-2027