Finding 1208584 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-04-23

AI Summary

  • Core Issue: The University failed to report student enrollment status changes to the National Student Loan Data System (NSLDS) accurately and on time, leading to a material weakness in internal controls.
  • Impacted Requirements: Non-compliance with 34 CFR 685.309 (b)(2)(ii) regarding timely reporting of student status changes, risking inaccurate loan status records and potential regulatory sanctions.
  • Recommended Follow-Up: Management should create formal procedures for enrollment reporting, assign responsibilities, maintain documentation, and conduct regular reviews to ensure compliance with federal reporting timelines.

Finding Text

Federal Program Federal PELL Grant Program ALN 84.063 Federal Direct Student Loan Program (DL) ALN. 84.268 Name of Federal Agency U.S. Department of Education (USDE) Pass-through Entity N/A Finding Type Material Weakness in Internal Control over Compliance Criteria According to 34 CFR 685.309 (b)(2)(ii) states that unless it expects to submit its next updated enrollment report to the Secretary within the next sixty (60) days, a school must notify the Secretary within thirty (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 9 students who graduated and/or withdrew during 2025, we noted the following instances of non-compliance: 1. Four (4) students for which the University did not report to the National Student Loan Data System (NSLDS) the student status changes. 2. One (1) student for which the University did not report to the National Student Loan Data System (NSLDS) the student status changes within the required 60 days’ period. 3. Two (2) students for which the University did not report the correct student status changes to the National Student Loan Data System (NSLDS).Cause The Institution did not establish and maintain adequate internal controls to ensure and document compliance with the Enrollment Reporting requirement Effect Failure to timely and accurately report enrollment status information may result in: • Inaccurate student loan status records. • Improper grace periods, deferments, or repayment status determinations. • Noncompliance with federal regulations. • Increased risk of regulatory sanctions or other administrative action by the U.S. Department of Education. Questioned Cost None Identification of a Repeat Finding This is a repeat finding from the immediate previous year’s audit (Finding No. 2024-001). Context Of the 41 status changes for 2025, we selected 9 students for testing and noted 7 instances in which the University did not comply with the enrollment reporting requirements. Views of Responsible Officials and Planned Corrective Actions The University management agrees with this finding. Responsible Official Francisco Ortiz, President (787) 761-0640. Please refer to the corrective action plan on pages 40. Recommendation Management should reassess the process and timeframe in which the University submits the information to the National Student Loan Data System and monitoring to ensure they comply with the reporting timeframe. We recommend that the Institution: 1. Develop and implement formal written procedures for Enrollment Reporting. 2. Assign clear responsibility to designated personnel. 3. Maintain documentation evidencing each submission and confirmation of acceptance by NSLDS. 4. Implement periodic supervisory review to ensure reporting occurs at least every 60 days in accordance with federal requirements. The University should enhance both electronic and manual procedures to ensure enrollment status changes are timely and accurately reported to the National Student Loan Data System.

Corrective Action Plan

Institutional Comments on Findings and Recommendations: The institution agrees with the auditor on this finding that there were (4) four cases where the changes to the student enrollment status were not reported. The institution also agrees with the auditor that there was (1) one case where the enrollment status was not reported within the required 60 days' period. The institution also agrees with the auditor that there were (2) two cases where the correct student status was not reported to NSLDS. The institution has identified cases where the information was reported correctly or timely on one monthly report and in the following report some of the information is missing or identified as not reported correctly or was just eliminated from the enrollment listings. This occurred especially in the cases as notified with a status change to W (withdrawal) and G (graduated) The institution, has contacted the NDSLS Help Desk to be able to resolve such issues and others as related to the NSLDS report tools section of the revised NSLDS platform. Actions Taken or Planned: Although the institution is scheduled to report to NSLDS every 60 days, the institution would continue to submit its Enrollment Reports monthly to notify changes of student status to the Department of Education in order to do so on a timely basis. The institution has always had a personnel member designated for the compliance of the Enrollment submission process as required and has discussed the matters as related to the auditor's findings with said personnel. Following the recommendation of the auditors, the institution would proceed to document each submission and confirmation of acceptance by NSLDS of the changes submitted to the Department of Education as regards to Enrollment Reporting. Status of Corrective Actions on Prior Findings: Some of the issues related to this finding occurred in the past audit.

Categories

Student Financial Aid Subrecipient Monitoring

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $748,245
84.268 Federal Direct Student Loans Program $549,294