Finding 513000 (2024-003)

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

AI Summary

  • Core Issue: The University failed to return Title IV funds for three students within the required 45 days after withdrawal, impacting compliance with federal regulations.
  • Impacted Requirements: Non-compliance with 34 CFR § 668.22(j) can lead to financial liabilities and penalties, affecting federal financial aid participation.
  • Recommended Follow-Up: Implement better monitoring controls in the financial aid system and train staff to ensure timely returns of unearned Title IV funds.

Finding Text

Finding No. 2024-003 Timely Return on Title IV Funds Federal Program ALN 84.063 Federal Pell Grant Program Name of Federal Agency U.S. Department of Education Category Other matters – N. Special test Return of Title IV Funds Significant deficiency of internal controls over compliance Criteria Under 34 CFR § 668.22(j), An institution must return the amount of title IV funds for which it is responsible under paragraph (g) as soon as possible but no later than 45 days after the date of the institution's determination that the student withdrew. Condition found In testing compliance with the return of Title IV funds requirement, we noted three (3) cases, or eight percent (8%), of the sample selected which included students that received Pell and Direct loans, in which the University failed to return the total corresponding refund within 45 days from the date the University determined that the student withdrew, dropped-out, or failed to attend to the University, as follows: Finding Number Related Audit Compliance Requirement Student Identifier OPEID Pell Disbursed ($) Pell Underpayment ($) Pell Overpayment ($) Direct Loan Disbursed ($) Direct Loan Underpayment ($) Direct Loan Overpayment ($) 2024-003 Special Tests - Timely Return of Title IV Funds Student 1 1072401 $ 3,698 $ - $ - $ - $ - $ - 2024-003 Special Tests - Timely Return of Title IV Funds Student 2 1072401 $ 3,323 $ - $ - $ - $ - $ - 2024-003 Special Tests - Timely Return of Title IV Funds Student 3 1072401 $ 3,698 $ - $ - $ - $ - $ - Cause The return of tittle IV funds calculation process was conducted and completed on time in the Student Financial Assistance (SFA) office. However, updating the SFA module in Ellucian (school ISIS) was not flagged as valid. This omission meant that the University was unable to generate a cancelation payroll to close the transaction. Effect Failure to return unearned Title IV funds within the required 45-day timeframe can result in potential financial liabilities for the institution, non-compliance penalties, and a negative impact on the institution's participation in federal financial aid programs. Questioned cost None. The funds were returned. Context Three (3) of eleven (11) withdrawal forms from students who received Pell Grants from both campuses reviewed were not timely reimbursed to the Department of Education. The total amount of funds returned late was $5,688 out of a total of $10,512 for the campus of Miami. Identification of a repeat finding This is not a repeat finding from the immediate previous audit. Recommendation We recommend that the institution implement enhanced monitoring controls within the financial aid system to ensure that all return of tittle IV funds calculations trigger the necessary flags to prompt timely returns of unearned Title IV funds. Additionally, staff should be trained in monitoring these processes to prevent further delays in compliance with federal regulations. The institution should address the deficiencies noted and review all return of tittle IV funds processes to avoid recurrence and to ensure compliance. 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. 2024-003 Late R2T4 reimbursement to ED Condition Found In testing compliance with the return of Title IV funds requirement, we noted three (3) cases, or eight percent (8%), of the sample selected, in which the University failed to return the total corresponding refund within 45 days from the date the University determined that the student withdrew, dropped-out, or failed to attend to the University. Corrective Action Plan The institution will enhance the total withdrawal process by assigning a dedicated financial aid officer to each campus, responsible for overseeing all funds. This officer will be solely accountable for determining whether a withdrawal is official or unofficial, executing the Return of Title IV (R2T4) process, and coordinating with the fiscal department to ensure timely completion of refunds. As a further safeguard, the Title IV Compliance Coordinator will rigorously monitor the effectiveness of this corrective action plan and ensure ongoing compliance. Name(s) of the Contact Person(s) Responsible for Corrective Action Doris Quero, Senior Financial Aid Director Carmen Rivera Laboy, Title IV Compliance Coordinator Anticipated Completion Date Will be completed on or before January 15, 2025.

Categories

Student Financial Aid Subrecipient Monitoring Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 512998 2024-001
    Significant Deficiency Repeat
  • 512999 2024-002
    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