Finding 512998 (2024-001)

Significant Deficiency Repeat Finding
Requirement
CN
Questioned Costs
-
Year
2024
Accepted
2024-12-04
Audit: 330883
Organization: Universidad Carlos Albizu, Inc. (PR)
Auditor: Galindez LLC

AI Summary

  • Core Issue: Excess cash was held for over ten days due to delays in returning funds, violating federal regulations.
  • Impacted Requirements: The university failed to comply with 34 CFR 668.166 regarding timely disbursement and return of federal funds.
  • Recommended Follow-Up: Establish clear procedures and monitoring systems for timely fund returns, specifying responsible personnel and regular reviews.

Finding Text

Finding No. 2024-001 Excess cash Federal Program ALN 84.268 Federal Direct Student Loans Program Name of Federal Agency U.S. Department of Education Category Other matters – C. Cash Management; N. Special test Return of Title IV Funds Significant deficiency of internal controls over compliance Criteria As per the Code of Federal Regulations 34 CFR 668.166: Excess cash is any amount of FSA funds, other than Federal Perkins Loan Program funds, that an institution does not disburse to students or parents by the end of the third business day following the date the institution received those funds from the Department; or deposited or transferred to its depository account previously disbursed FSA funds received from the Department, such as those resulting from award adjustments, recoveries, or cancellations. Sometimes a school cannot disburse funds in the required three business days because of circumstances outside the school’s control. If unusual circumstances exist, an institution may retain an excess cash tolerance for up to seven calendar days for an additional amount of excess cash that does not exceed one percent of the total amount of funds the institution drew down in the prior award year. The school must immediately return to the Department any amount of excess cash over the one-percent tolerance and any amount of excess cash remaining in its account after the additional seven-day tolerance period. Condition found In nine (9) of fifty-three (53) return drawdowns from the San Juan Campus, adjustments were not properly returned on G-5, creating excess cash for more than the required period of ten (10) days (three (3) business days plus an additional seven (7) calendar days). In addition, refunds were not returned on G-5 in a timely manner during the required period of thirty (30) days. Return date Return Amount Return on G-5 date Days passed 01/10/2024 $ (6,761) 03/06/24 56 01/11/2024 (6,761) 03/06/24 55 01/11/2024 (6,761) 03/06/24 55 01/16/2024 (4,948) 03/06/24 50 01/16/2024 (9,895) 03/06/24 50 01/18/2024 (6,761) 03/06/24 48 01/18/2024 (5,244) 03/06/24 48 01/22/2024 (16,656) 03/06/24 44 01/24/2024 (10,884) 03/06/24 42 $ (74,671) Cause Miscommunication between the finance departments and financial aid of San Juan campus. The financial aid department communicated the adjustments in students enrollment but the finance department did not returned the funds on time. In addition, lack of monitoring of excess of cash led to the condition. Effect Return of funds in G-5 took longer than the ten-day tolerance period, resulting in excess cash. Upon a finding that an institution maintained excess cash for any amount or time over that allowed in the tolerance provisions in paragraph (b) of section § 668.166, the actions the Secretary may take include, but are not limited to— (1) Requiring the institution to reimburse the Secretary for the costs the Federal government incurred in providing that excess cash to the institution; and (2) Providing funds to the institution under the reimbursement payment method or heightened cash monitoring payment method described in § 668.162(c) and (d), respectively. Questioned cost None. The funds were returned. Context Total amount of funds returned that were late was $74,671 out of a total of $395,282 for the campus of San Juan. The average of days passed between disbursement date and date of return of funds was approximately 50 days. Return of funds corresponds to adjustments in students enrollment after the drawdown of funds on G-5 system. Identification of a repeat finding Yes. This is an immediate repeat of prior year finding 2023-001. Recommendation We recommend that the University include specific processes for returning funds in its internal procedures and policies. These procedures need to include the time frame for returning funds and the personnel responsible for it. This will assist in safeguarding the timeliness and accuracy of the funds returned to the federal program. In addition to specifying time frames and responsible personnel for the return of federal funds, the University should implement a monitoring system to track these transactions and implement a system of periodic reviews that ensure the procedures remain up to date with cash management regulations. Views of responsible officials and planned corrective actions The University’s management agrees with this finding. Please refer to the corrective action plan on pages 60-63.

Corrective Action Plan

Finding No. 2024-001 Excess of Cash Condition Found In nine (9) of fifty-three (53) return drawdowns from the San Juan Campus, returns were not properly returned on G-5, creating excess cash for more than the required period of ten (10) days (3 business days plus an additional seven calendar days). In addition, refunds were not returned on G-5 in a timely manner during the required period of thirty (30) days. Corrective Action Plan The institution will appoint a dedicated G-5 administrator in Puerto Rico, independent of the Miami office, to ensure compliance. This role will be complemented by the active pursuit and implementation of advanced system functionalities designed to enhance the identification of student cases and automate and streamline processes. This comprehensive initiative will not only fortify existing procedures but will also significantly enhance operational efficiency and accountability, with an immediate escalation protocol requiring that any delays or processing issues be reported to management for prompt resolution. Name(s) of the Contact Person(s) Responsible for Corrective Action Héctor L. Peña, Director of Finance Ramón L. Menéndez, CFO Dr. Antonio Llorens, CIO Anticipated Completion Date Will be completed on or before December 15, 2024

Categories

Cash Management Student Financial Aid

Other Findings in this Audit

  • 512999 2024-002
    Significant Deficiency
  • 513000 2024-003
    Significant Deficiency
  • 513001 2024-004
    Significant Deficiency
  • 1089440 2024-001
    Significant Deficiency Repeat
  • 1089441 2024-002
    Significant Deficiency
  • 1089442 2024-003
    Significant Deficiency
  • 1089443 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $46.58M
84.063 Federal Pell Grant Program $5.43M
93.556 Marylee Allen Promoting Safe and Stable Families Program $2.25M
84.425 Education Stabilization Fund $1.84M
84.031 Higher Education Institutional Aid $1.06M
84.184 School Safely National Activities $847,383
93.925 Scholarships for Health Professions Students From Disadvantaged Backgrounds $675,000
93.191 Graduate Psychology Education $592,372
84.033 Federal Work-Study Program $555,826
84.116 Fund for the Improvement of Postsecondary Education $296,728
84.007 Federal Supplemental Educational Opportunity Grants $46,000
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $3,980