Finding 382380 (2023-001)

- Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-03-20

AI Summary

  • Core Issue: One student’s withdrawal was not processed within the required 30-day timeframe, leading to noncompliance with Title IV funds regulations.
  • Impacted Requirements: The university failed to determine withdrawal dates as mandated by 34 CFR 668.22(j)(2), risking penalties from the U.S. Department of Education.
  • Recommended Follow-up: Management should enhance procedures to ensure timely identification and processing of student withdrawals to prevent future noncompliance.

Finding Text

Finding No. 2023–001 - Special Tests and Provisions - Return of Title IV Funds - San Germán Campus Federal Program Name Student Financial Assistance Programs Cluster - Federal Direct Student Loan Program (DL) Assistance Listing 84.268 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 thirteen (13) students from the selected campuses that failed to earn a passing grade, for a total of seventy three (73) students, and noted that for one (1) student, the determination of withdrawal was performed after the required 30 days, as follows: Table Cause At the end of the term in the San Germán campus, the professor certified a non-passing grade and later changed it to an unauthorized withdrawal, resulting in an administrative withdrawal for the student. However, such administrative withdrawal was not determined within the required period. 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 2,417 withdrawals from the selected campuses for the year ended June 30, 2023, we selected sixty (60) students who withdrew, dropped-out, or failed to attend to the University, plus all thirteen (13) students from the selected campuses that failed to earn a passing grade, for a total of seventy-three (73) 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: 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: Table Identification of a Repeat Finding This is a repeat finding from the immediate previous audit (2022-001). Recommendation The University San Germán 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 66-67.

Corrective Action Plan

Corrective Action Plan The Inter American University of Puerto Rico (IAUPR) will implement the following actions to strengthen compliance with the 30-day reglementary period for the R2T4 determination: 1. IAUPR will also prepare compulsory online or face-to-face training sessions which all full and part-time faculty will be required to take in August and January of each year. The training sessions will review grading policies and any other procedures required for compliance with Federal Regulations. The primary executives of each academic unit, through the Deans of Academic Affairs, will be responsible for ensuring and certifying to the Vice President of Academic and Student Affairs that all faculty participated in the training. 2. The Deans of Academic Affairs or their designees at each academic unit will monitor the entry of final grades in the Banner System and report any suspicious grades and suspected cases of noncompliance with Federal Regulations to the chairs of the academic departments for immediate follow-up and correction. 3. IAUPR will develop a course of action whereby a department chair or dean of academic affairs may correct or update a grade in the Banner System, based on the academic information available, when a faculty member is unable to do so because of a force majeure. 4. In recurrent cases of noncompliance, the primary executives of each academic unit will send a written communication to faculty that do not comply with established procedures and include a copy of the communication in the professors' academic/administrative files.

Categories

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking Subrecipient Monitoring Eligibility

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $97.98M
84.268 Federal Direct Student Loans $62.99M
84.031 Higher Education_institutional Aid $3.42M
84.007 Federal Supplemental Educational Opportunity Grants $2.85M
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $2.16M
84.047 Trio_upward Bound $1.78M
84.033 Federal Work-Study Program $1.58M
84.066 Trio_educational Opportunity Centers $1.02M
47.076 Education and Human Resources $872,937
84.042 Trio_student Support Services $626,956
84.120 Minority Science and Engineering Improvement $536,104
84.002 Adult Education - Basic Grants to States $530,409
84.149 Migrant Education_college Assistance Migrant Program $481,195
84.141 Migrant Education_high School Equivalency Program $436,259
84.335 Child Care Access Means Parents in School $343,886
16.575 Crime Victim Assistance $335,521
93.859 Biomedical Research and Research Training $300,909
10.223 Hispanic Serving Institutions Education Grants $286,997
84.217 Trio_mcnair Post-Baccalaureate Achievement $284,878
84.425 Education Stabilization Fund $268,509
84.044 Trio_talent Search $243,929
21.027 Coronavirus State and Local Fiscal Recovery Funds $242,131
59.037 Small Business Development Centers $215,863
93.178 Nursing Workforce Diversity $151,121
10.310 Agriculture and Food Research Initiative (afri) $131,146
81.123 National Nuclear Security Administration (nnsa) Minority Serving Institutions (msi) Program $109,015
47.050 Geosciences $105,459
47.074 Biological Sciences $102,788
47.079 Office of International Science and Engineering $87,753
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $80,669
43.001 Science $72,035
10.443 Outreach and Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers $55,425
93.586 State Court Improvement Program $48,390
20.109 Air Transportation Centers of Excellence $43,477
43.008 Education $40,305
15.657 Endangered Species Conservation Ð Recovery Implementation Funds $37,784
59.058 Federal and State Technology Partnership Program $29,773
19.750 Bureau of Western Hemisphere Affairs (wha) Grant Programs (including Energy and Climate Partnership for the Americas) $25,000
15.634 State Wildlife Grants $22,511
17.259 Wia Youth Activities $22,508
84.116 Fund for the Improvement of Postsecondary Education $18,739
16.746 Capital Case Litigation Initiative $18,545
93.124 Nurse Anesthetist Traineeships $14,003
10.902 Soil and Water Conservation $11,840
12.630 Basic, Applied, and Advanced Research in Science and Engineering $11,464
10.675 Urban and Community Forestry Program $8,269
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $7,914
16.029 Office on Violence Against Women Special Projects $6,617
45.312 National Leadership Grants $5,335
10.318 Women and Minorities in Science, Technology, Engineering, and Mathematics Fields $2,238