Audit 299620

Internal Controls Over the Fiscal Operations Report and Application to Participate (FISAP) Assistance Listing: 84.033 Program Title: Student Financial Aid Cluster Federal Agency: Department of Education Criteria The College is required to submit the FISAP which includes information that the Department of Education has determined to be critical with regard to the Federal Work-Study (FWS) Program. Condition The amount on line 12 of Section C of Part V of the FISAP - Total earned compensation for FWS Program did not agree to supporting documentation. Context The amount reported on the FISAP of $67,196 was $1,275 less than the College’s supporting payroll records for FWS. Effect Insufficient internal controls over the FISAP can result in errors in the amounts reported to the Department of Education. Cause The FISAP did not include all FWS payment periods. Recommendation We recommend that the College strengthen review procedures over the FISAP to ensure accuracy. Management’s Response The College will implement a two-step process to verify the FWS earnings on the FISAP. The Financial Aid Director and Manager of Compliance will develop a checklist to include verifying payroll records/reports. The checklist will be reviewed to confirm the accuracy of data reported on the FISAP.

Inadequate Maintenance of Records Supporting Cash Management Process Assistance Listing: 84.042, 84.044 and 84.047 Program Title: TRIO Cluster Federal Agency: Department of Education Criteria 2 CFR §200.305(b) states that “For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance of redemption of checks, warrants, or payments by other means.” Condition The College receives funding on the reimbursement method. However, for 10 out of 40 expenses sampled (1 for Student Support Services, 4 for Talent Search and 5 for Upward), we were unable to obtain information indicating when the expenses were submitted for reimbursement and therefore could not determine that the payments were made prior to reimbursement. In addition, for 2 out of 9 reimbursement requests tested (one for Upword Bound and one for Student Support Services) the College could not provide detail as to what expenses made up the requests. The two requests totaled $112,527 and the total requests tested totaled $282,815. Effect As a result of the lack of an audit trail, we were unable to determine compliance with cash management requirements for some expenses. Cause All exceptions occurred during the first half of the year prior to the hiring of a new Manager of Account Services. Recommendation We recommend that the College develop procedures to ensure that documentation supporting cash drawdowns is maintained and that all disbursements are included in a request for reimbursement. Management’s Response There are 10 audit findings total in calendar year 2022 and all are connected to a former staff person. In January 2023, we hired a new Manager of Account Services who immediately implemented new procedures and prepared the appropriate level of detail backup information for the TRIO reimbursements. Each reimbursement was also signed by the Controller, who verified the information and transactions before any funds were transferred. This process currently complies with cash management requirements.

Inadequate Maintenance of Records Supporting Cash Management Process Assistance Listing: 84.042, 84.044 and 84.047 Program Title: TRIO Cluster Federal Agency: Department of Education Criteria 2 CFR §200.305(b) states that “For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance of redemption of checks, warrants, or payments by other means.” Condition The College receives funding on the reimbursement method. However, for 10 out of 40 expenses sampled (1 for Student Support Services, 4 for Talent Search and 5 for Upward), we were unable to obtain information indicating when the expenses were submitted for reimbursement and therefore could not determine that the payments were made prior to reimbursement. In addition, for 2 out of 9 reimbursement requests tested (one for Upword Bound and one for Student Support Services) the College could not provide detail as to what expenses made up the requests. The two requests totaled $112,527 and the total requests tested totaled $282,815. Effect As a result of the lack of an audit trail, we were unable to determine compliance with cash management requirements for some expenses. Cause All exceptions occurred during the first half of the year prior to the hiring of a new Manager of Account Services. Recommendation We recommend that the College develop procedures to ensure that documentation supporting cash drawdowns is maintained and that all disbursements are included in a request for reimbursement. Management’s Response There are 10 audit findings total in calendar year 2022 and all are connected to a former staff person. In January 2023, we hired a new Manager of Account Services who immediately implemented new procedures and prepared the appropriate level of detail backup information for the TRIO reimbursements. Each reimbursement was also signed by the Controller, who verified the information and transactions before any funds were transferred. This process currently complies with cash management requirements.

Inadequate Maintenance of Records Supporting Cash Management Process Assistance Listing: 84.042, 84.044 and 84.047 Program Title: TRIO Cluster Federal Agency: Department of Education Criteria 2 CFR §200.305(b) states that “For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance of redemption of checks, warrants, or payments by other means.” Condition The College receives funding on the reimbursement method. However, for 10 out of 40 expenses sampled (1 for Student Support Services, 4 for Talent Search and 5 for Upward), we were unable to obtain information indicating when the expenses were submitted for reimbursement and therefore could not determine that the payments were made prior to reimbursement. In addition, for 2 out of 9 reimbursement requests tested (one for Upword Bound and one for Student Support Services) the College could not provide detail as to what expenses made up the requests. The two requests totaled $112,527 and the total requests tested totaled $282,815. Effect As a result of the lack of an audit trail, we were unable to determine compliance with cash management requirements for some expenses. Cause All exceptions occurred during the first half of the year prior to the hiring of a new Manager of Account Services. Recommendation We recommend that the College develop procedures to ensure that documentation supporting cash drawdowns is maintained and that all disbursements are included in a request for reimbursement. Management’s Response There are 10 audit findings total in calendar year 2022 and all are connected to a former staff person. In January 2023, we hired a new Manager of Account Services who immediately implemented new procedures and prepared the appropriate level of detail backup information for the TRIO reimbursements. Each reimbursement was also signed by the Controller, who verified the information and transactions before any funds were transferred. This process currently complies with cash management requirements.

Inaccurate or Unsupported Information on Annual Performance Reports Assistance Listing: 84.042, 84.044 and 84.047 Program Title: TRIO Cluster Federal Agency: Department of Education Criteria Annual Performance Reports must be submitted annually and the Compliance Supplement identifies certain line items as containing critical information. Condition For the Student Support Services Annual Performance Report, the following were noted: 1. One out of five students sampled included a different program admittance date (5/1/2019) than what was on the applicant review form (10/1/2019). 2. One out of five students sampled included a different College grade level than what was indicated on the applicant review form. For the Talent Search Annual Performance Report, the following were noted: 1. For 3 out of 17 students sampled, the College was unable to obtain transcripts to verify the requirement that the students received regular secondary school diplomas within the standard number of years but did not complete a rigorous program of study. 2. For 4 out of 17 students sampled, the College was unable to verify that the student enrolled in post-secondary education or notified of deferred enrollment. 3. For one of 17 students sampled, the student’s grade level upon entering the program did not match that on the application. For one out of 3 students tested for the Talent Search Annual Performance Report, the date of first project service differed from the application and the student was indicated as a new participant but should have been reported as a continuing participant. Context A similar finding with regards to Upward Bound was reported as 2020-004. Effect When critical information contained in annual performance reports cannot be substantiated by, or is in conflict with, supporting documentation, erroneous information could be reported to the Department of Education. Cause For the instances where information conflicted with the application documentation, the cause was data entry errors. For the instances where there was no verification of secondary school diplomas or post-secondary school enrollment, the College indicated that attempts to obtain the information were unsuccessful. Recommendation We recommend that the College review their controls over the annual reporting process related to the TRIO programs and establish improved review and verification procedures to ensure the accuracy of the reports. Management’s Response The Director of TRIO SSS and TRIO ETS supervisor, the Dean of Equity and Inclusion, will conduct a spot check twice annually. Additionally, before submission of Annual Performance Report, the direct supervisor for all TRIO programs will review and spot check submissions.

Inaccurate or Unsupported Information on Annual Performance Reports Assistance Listing: 84.042, 84.044 and 84.047 Program Title: TRIO Cluster Federal Agency: Department of Education Criteria Annual Performance Reports must be submitted annually and the Compliance Supplement identifies certain line items as containing critical information. Condition For the Student Support Services Annual Performance Report, the following were noted: 1. One out of five students sampled included a different program admittance date (5/1/2019) than what was on the applicant review form (10/1/2019). 2. One out of five students sampled included a different College grade level than what was indicated on the applicant review form. For the Talent Search Annual Performance Report, the following were noted: 1. For 3 out of 17 students sampled, the College was unable to obtain transcripts to verify the requirement that the students received regular secondary school diplomas within the standard number of years but did not complete a rigorous program of study. 2. For 4 out of 17 students sampled, the College was unable to verify that the student enrolled in post-secondary education or notified of deferred enrollment. 3. For one of 17 students sampled, the student’s grade level upon entering the program did not match that on the application. For one out of 3 students tested for the Talent Search Annual Performance Report, the date of first project service differed from the application and the student was indicated as a new participant but should have been reported as a continuing participant. Context A similar finding with regards to Upward Bound was reported as 2020-004. Effect When critical information contained in annual performance reports cannot be substantiated by, or is in conflict with, supporting documentation, erroneous information could be reported to the Department of Education. Cause For the instances where information conflicted with the application documentation, the cause was data entry errors. For the instances where there was no verification of secondary school diplomas or post-secondary school enrollment, the College indicated that attempts to obtain the information were unsuccessful. Recommendation We recommend that the College review their controls over the annual reporting process related to the TRIO programs and establish improved review and verification procedures to ensure the accuracy of the reports. Management’s Response The Director of TRIO SSS and TRIO ETS supervisor, the Dean of Equity and Inclusion, will conduct a spot check twice annually. Additionally, before submission of Annual Performance Report, the direct supervisor for all TRIO programs will review and spot check submissions.

Inaccurate or Unsupported Information on Annual Performance Reports Assistance Listing: 84.042, 84.044 and 84.047 Program Title: TRIO Cluster Federal Agency: Department of Education Criteria Annual Performance Reports must be submitted annually and the Compliance Supplement identifies certain line items as containing critical information. Condition For the Student Support Services Annual Performance Report, the following were noted: 1. One out of five students sampled included a different program admittance date (5/1/2019) than what was on the applicant review form (10/1/2019). 2. One out of five students sampled included a different College grade level than what was indicated on the applicant review form. For the Talent Search Annual Performance Report, the following were noted: 1. For 3 out of 17 students sampled, the College was unable to obtain transcripts to verify the requirement that the students received regular secondary school diplomas within the standard number of years but did not complete a rigorous program of study. 2. For 4 out of 17 students sampled, the College was unable to verify that the student enrolled in post-secondary education or notified of deferred enrollment. 3. For one of 17 students sampled, the student’s grade level upon entering the program did not match that on the application. For one out of 3 students tested for the Talent Search Annual Performance Report, the date of first project service differed from the application and the student was indicated as a new participant but should have been reported as a continuing participant. Context A similar finding with regards to Upward Bound was reported as 2020-004. Effect When critical information contained in annual performance reports cannot be substantiated by, or is in conflict with, supporting documentation, erroneous information could be reported to the Department of Education. Cause For the instances where information conflicted with the application documentation, the cause was data entry errors. For the instances where there was no verification of secondary school diplomas or post-secondary school enrollment, the College indicated that attempts to obtain the information were unsuccessful. Recommendation We recommend that the College review their controls over the annual reporting process related to the TRIO programs and establish improved review and verification procedures to ensure the accuracy of the reports. Management’s Response The Director of TRIO SSS and TRIO ETS supervisor, the Dean of Equity and Inclusion, will conduct a spot check twice annually. Additionally, before submission of Annual Performance Report, the direct supervisor for all TRIO programs will review and spot check submissions.

Inadequate Internal Controls Over Eligibility Assistance Listing: 84.047 Program Title: TRIO Cluster – Upward Bound Federal Agency: Department of Education Criteria The College’s controls over student eligibility for the TRIO Upward Bound program include the following: 1. Students and parents/guardians must complete and sign an application. 2. Applications are reviewed by program staff to determine whether a student meets the proper requirements to participate in the program. 3. If such requirements are met, an acceptance letter signed by the Upward Bound Director is provided to students and their parent/guardian stating that they have been accepted into the program. Condition Out of 5 Upward Bound Program applications tested, one was not signed by the parent or guardian, one was not signed by the student and an incomplete application was provided for another student which prevented us from determining whether or not it was properly signed. In addition, an acceptance letter was not available for the student for which a complete application was not provided. Context A similar finding was reported as 2020-003. Effect Ineffective controls over participant eligibility can result in ineligible participation in the federal program. Cause The finding appears to be the result of oversight by the prior TRIO Upward Bound staff. Recommendation The College should strengthen controls over the review of and maintenance of applications and acceptance letters. Management’s Response TRIO Upward Bound has new leadership from the Director up to the Vice President. The new Director has already implemented a new set of protocols to verify all eligibility markers are met. The Director's supervisor, the Dean of Equity and Inclusion, will conduct a spot check twice annually.

Lack of Compliance With Required Use of HEERF III Funds Assistance Listing: 84.425F Program Title: Education Stabilization Fund: ARP HEERF III Federal Agency: Department of Education Criteria The Higher Education Emergency Relief Fund III Frequently Asked Questions provides that a portion of the institutional funds must be used to “Conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances described in section 479A of the HEA.” Condition The College did not use a portion of the HEERF III funding for the above mentioned purpose. Context This requirement was one of two new requirements. The other requirement to use funding to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines was followed by the College. Effect The College did not comply with one of the required uses of their grant funding. Cause Unknown. Recommendation We recommend that management review grant requirements in order to ensure compliance. Management’s Response The HEERF III Funds were provided to the College as a result of the recent pandemic. These grant funds are no longer available to the College. While we did not effectively market or engage in outreach to students to provide financial aid adjustments, we instead provided hard dollars to all students using these grant funds to offset any financial circumstances related to employment.

Internal Controls Over the Fiscal Operations Report and Application to Participate (FISAP) Assistance Listing: 84.033 Program Title: Student Financial Aid Cluster Federal Agency: Department of Education Criteria The College is required to submit the FISAP which includes information that the Department of Education has determined to be critical with regard to the Federal Work-Study (FWS) Program. Condition The amount on line 12 of Section C of Part V of the FISAP - Total earned compensation for FWS Program did not agree to supporting documentation. Context The amount reported on the FISAP of $67,196 was $1,275 less than the College’s supporting payroll records for FWS. Effect Insufficient internal controls over the FISAP can result in errors in the amounts reported to the Department of Education. Cause The FISAP did not include all FWS payment periods. Recommendation We recommend that the College strengthen review procedures over the FISAP to ensure accuracy. Management’s Response The College will implement a two-step process to verify the FWS earnings on the FISAP. The Financial Aid Director and Manager of Compliance will develop a checklist to include verifying payroll records/reports. The checklist will be reviewed to confirm the accuracy of data reported on the FISAP.

Inadequate Maintenance of Records Supporting Cash Management Process Assistance Listing: 84.042, 84.044 and 84.047 Program Title: TRIO Cluster Federal Agency: Department of Education Criteria 2 CFR §200.305(b) states that “For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance of redemption of checks, warrants, or payments by other means.” Condition The College receives funding on the reimbursement method. However, for 10 out of 40 expenses sampled (1 for Student Support Services, 4 for Talent Search and 5 for Upward), we were unable to obtain information indicating when the expenses were submitted for reimbursement and therefore could not determine that the payments were made prior to reimbursement. In addition, for 2 out of 9 reimbursement requests tested (one for Upword Bound and one for Student Support Services) the College could not provide detail as to what expenses made up the requests. The two requests totaled $112,527 and the total requests tested totaled $282,815. Effect As a result of the lack of an audit trail, we were unable to determine compliance with cash management requirements for some expenses. Cause All exceptions occurred during the first half of the year prior to the hiring of a new Manager of Account Services. Recommendation We recommend that the College develop procedures to ensure that documentation supporting cash drawdowns is maintained and that all disbursements are included in a request for reimbursement. Management’s Response There are 10 audit findings total in calendar year 2022 and all are connected to a former staff person. In January 2023, we hired a new Manager of Account Services who immediately implemented new procedures and prepared the appropriate level of detail backup information for the TRIO reimbursements. Each reimbursement was also signed by the Controller, who verified the information and transactions before any funds were transferred. This process currently complies with cash management requirements.

Inadequate Maintenance of Records Supporting Cash Management Process Assistance Listing: 84.042, 84.044 and 84.047 Program Title: TRIO Cluster Federal Agency: Department of Education Criteria 2 CFR §200.305(b) states that “For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance of redemption of checks, warrants, or payments by other means.” Condition The College receives funding on the reimbursement method. However, for 10 out of 40 expenses sampled (1 for Student Support Services, 4 for Talent Search and 5 for Upward), we were unable to obtain information indicating when the expenses were submitted for reimbursement and therefore could not determine that the payments were made prior to reimbursement. In addition, for 2 out of 9 reimbursement requests tested (one for Upword Bound and one for Student Support Services) the College could not provide detail as to what expenses made up the requests. The two requests totaled $112,527 and the total requests tested totaled $282,815. Effect As a result of the lack of an audit trail, we were unable to determine compliance with cash management requirements for some expenses. Cause All exceptions occurred during the first half of the year prior to the hiring of a new Manager of Account Services. Recommendation We recommend that the College develop procedures to ensure that documentation supporting cash drawdowns is maintained and that all disbursements are included in a request for reimbursement. Management’s Response There are 10 audit findings total in calendar year 2022 and all are connected to a former staff person. In January 2023, we hired a new Manager of Account Services who immediately implemented new procedures and prepared the appropriate level of detail backup information for the TRIO reimbursements. Each reimbursement was also signed by the Controller, who verified the information and transactions before any funds were transferred. This process currently complies with cash management requirements.

Inadequate Maintenance of Records Supporting Cash Management Process Assistance Listing: 84.042, 84.044 and 84.047 Program Title: TRIO Cluster Federal Agency: Department of Education Criteria 2 CFR §200.305(b) states that “For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance of redemption of checks, warrants, or payments by other means.” Condition The College receives funding on the reimbursement method. However, for 10 out of 40 expenses sampled (1 for Student Support Services, 4 for Talent Search and 5 for Upward), we were unable to obtain information indicating when the expenses were submitted for reimbursement and therefore could not determine that the payments were made prior to reimbursement. In addition, for 2 out of 9 reimbursement requests tested (one for Upword Bound and one for Student Support Services) the College could not provide detail as to what expenses made up the requests. The two requests totaled $112,527 and the total requests tested totaled $282,815. Effect As a result of the lack of an audit trail, we were unable to determine compliance with cash management requirements for some expenses. Cause All exceptions occurred during the first half of the year prior to the hiring of a new Manager of Account Services. Recommendation We recommend that the College develop procedures to ensure that documentation supporting cash drawdowns is maintained and that all disbursements are included in a request for reimbursement. Management’s Response There are 10 audit findings total in calendar year 2022 and all are connected to a former staff person. In January 2023, we hired a new Manager of Account Services who immediately implemented new procedures and prepared the appropriate level of detail backup information for the TRIO reimbursements. Each reimbursement was also signed by the Controller, who verified the information and transactions before any funds were transferred. This process currently complies with cash management requirements.

Inaccurate or Unsupported Information on Annual Performance Reports Assistance Listing: 84.042, 84.044 and 84.047 Program Title: TRIO Cluster Federal Agency: Department of Education Criteria Annual Performance Reports must be submitted annually and the Compliance Supplement identifies certain line items as containing critical information. Condition For the Student Support Services Annual Performance Report, the following were noted: 1. One out of five students sampled included a different program admittance date (5/1/2019) than what was on the applicant review form (10/1/2019). 2. One out of five students sampled included a different College grade level than what was indicated on the applicant review form. For the Talent Search Annual Performance Report, the following were noted: 1. For 3 out of 17 students sampled, the College was unable to obtain transcripts to verify the requirement that the students received regular secondary school diplomas within the standard number of years but did not complete a rigorous program of study. 2. For 4 out of 17 students sampled, the College was unable to verify that the student enrolled in post-secondary education or notified of deferred enrollment. 3. For one of 17 students sampled, the student’s grade level upon entering the program did not match that on the application. For one out of 3 students tested for the Talent Search Annual Performance Report, the date of first project service differed from the application and the student was indicated as a new participant but should have been reported as a continuing participant. Context A similar finding with regards to Upward Bound was reported as 2020-004. Effect When critical information contained in annual performance reports cannot be substantiated by, or is in conflict with, supporting documentation, erroneous information could be reported to the Department of Education. Cause For the instances where information conflicted with the application documentation, the cause was data entry errors. For the instances where there was no verification of secondary school diplomas or post-secondary school enrollment, the College indicated that attempts to obtain the information were unsuccessful. Recommendation We recommend that the College review their controls over the annual reporting process related to the TRIO programs and establish improved review and verification procedures to ensure the accuracy of the reports. Management’s Response The Director of TRIO SSS and TRIO ETS supervisor, the Dean of Equity and Inclusion, will conduct a spot check twice annually. Additionally, before submission of Annual Performance Report, the direct supervisor for all TRIO programs will review and spot check submissions.

Inaccurate or Unsupported Information on Annual Performance Reports Assistance Listing: 84.042, 84.044 and 84.047 Program Title: TRIO Cluster Federal Agency: Department of Education Criteria Annual Performance Reports must be submitted annually and the Compliance Supplement identifies certain line items as containing critical information. Condition For the Student Support Services Annual Performance Report, the following were noted: 1. One out of five students sampled included a different program admittance date (5/1/2019) than what was on the applicant review form (10/1/2019). 2. One out of five students sampled included a different College grade level than what was indicated on the applicant review form. For the Talent Search Annual Performance Report, the following were noted: 1. For 3 out of 17 students sampled, the College was unable to obtain transcripts to verify the requirement that the students received regular secondary school diplomas within the standard number of years but did not complete a rigorous program of study. 2. For 4 out of 17 students sampled, the College was unable to verify that the student enrolled in post-secondary education or notified of deferred enrollment. 3. For one of 17 students sampled, the student’s grade level upon entering the program did not match that on the application. For one out of 3 students tested for the Talent Search Annual Performance Report, the date of first project service differed from the application and the student was indicated as a new participant but should have been reported as a continuing participant. Context A similar finding with regards to Upward Bound was reported as 2020-004. Effect When critical information contained in annual performance reports cannot be substantiated by, or is in conflict with, supporting documentation, erroneous information could be reported to the Department of Education. Cause For the instances where information conflicted with the application documentation, the cause was data entry errors. For the instances where there was no verification of secondary school diplomas or post-secondary school enrollment, the College indicated that attempts to obtain the information were unsuccessful. Recommendation We recommend that the College review their controls over the annual reporting process related to the TRIO programs and establish improved review and verification procedures to ensure the accuracy of the reports. Management’s Response The Director of TRIO SSS and TRIO ETS supervisor, the Dean of Equity and Inclusion, will conduct a spot check twice annually. Additionally, before submission of Annual Performance Report, the direct supervisor for all TRIO programs will review and spot check submissions.

Inaccurate or Unsupported Information on Annual Performance Reports Assistance Listing: 84.042, 84.044 and 84.047 Program Title: TRIO Cluster Federal Agency: Department of Education Criteria Annual Performance Reports must be submitted annually and the Compliance Supplement identifies certain line items as containing critical information. Condition For the Student Support Services Annual Performance Report, the following were noted: 1. One out of five students sampled included a different program admittance date (5/1/2019) than what was on the applicant review form (10/1/2019). 2. One out of five students sampled included a different College grade level than what was indicated on the applicant review form. For the Talent Search Annual Performance Report, the following were noted: 1. For 3 out of 17 students sampled, the College was unable to obtain transcripts to verify the requirement that the students received regular secondary school diplomas within the standard number of years but did not complete a rigorous program of study. 2. For 4 out of 17 students sampled, the College was unable to verify that the student enrolled in post-secondary education or notified of deferred enrollment. 3. For one of 17 students sampled, the student’s grade level upon entering the program did not match that on the application. For one out of 3 students tested for the Talent Search Annual Performance Report, the date of first project service differed from the application and the student was indicated as a new participant but should have been reported as a continuing participant. Context A similar finding with regards to Upward Bound was reported as 2020-004. Effect When critical information contained in annual performance reports cannot be substantiated by, or is in conflict with, supporting documentation, erroneous information could be reported to the Department of Education. Cause For the instances where information conflicted with the application documentation, the cause was data entry errors. For the instances where there was no verification of secondary school diplomas or post-secondary school enrollment, the College indicated that attempts to obtain the information were unsuccessful. Recommendation We recommend that the College review their controls over the annual reporting process related to the TRIO programs and establish improved review and verification procedures to ensure the accuracy of the reports. Management’s Response The Director of TRIO SSS and TRIO ETS supervisor, the Dean of Equity and Inclusion, will conduct a spot check twice annually. Additionally, before submission of Annual Performance Report, the direct supervisor for all TRIO programs will review and spot check submissions.

Inadequate Internal Controls Over Eligibility Assistance Listing: 84.047 Program Title: TRIO Cluster – Upward Bound Federal Agency: Department of Education Criteria The College’s controls over student eligibility for the TRIO Upward Bound program include the following: 1. Students and parents/guardians must complete and sign an application. 2. Applications are reviewed by program staff to determine whether a student meets the proper requirements to participate in the program. 3. If such requirements are met, an acceptance letter signed by the Upward Bound Director is provided to students and their parent/guardian stating that they have been accepted into the program. Condition Out of 5 Upward Bound Program applications tested, one was not signed by the parent or guardian, one was not signed by the student and an incomplete application was provided for another student which prevented us from determining whether or not it was properly signed. In addition, an acceptance letter was not available for the student for which a complete application was not provided. Context A similar finding was reported as 2020-003. Effect Ineffective controls over participant eligibility can result in ineligible participation in the federal program. Cause The finding appears to be the result of oversight by the prior TRIO Upward Bound staff. Recommendation The College should strengthen controls over the review of and maintenance of applications and acceptance letters. Management’s Response TRIO Upward Bound has new leadership from the Director up to the Vice President. The new Director has already implemented a new set of protocols to verify all eligibility markers are met. The Director's supervisor, the Dean of Equity and Inclusion, will conduct a spot check twice annually.

Lack of Compliance With Required Use of HEERF III Funds Assistance Listing: 84.425F Program Title: Education Stabilization Fund: ARP HEERF III Federal Agency: Department of Education Criteria The Higher Education Emergency Relief Fund III Frequently Asked Questions provides that a portion of the institutional funds must be used to “Conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances described in section 479A of the HEA.” Condition The College did not use a portion of the HEERF III funding for the above mentioned purpose. Context This requirement was one of two new requirements. The other requirement to use funding to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines was followed by the College. Effect The College did not comply with one of the required uses of their grant funding. Cause Unknown. Recommendation We recommend that management review grant requirements in order to ensure compliance. Management’s Response The HEERF III Funds were provided to the College as a result of the recent pandemic. These grant funds are no longer available to the College. While we did not effectively market or engage in outreach to students to provide financial aid adjustments, we instead provided hard dollars to all students using these grant funds to offset any financial circumstances related to employment.