Audit 381494

Finding 2025-001 – Required Services to Eligible Participants Type of Finding: Significant Deficiency and Compliance Federal Grant Name and ALN: TRIO Cluster: TRIO Educational Talent Search (84.044A) Federal Agency: U.S. Department of Education (Grant ID P-044A210563-23) Compliance Requirement: N. Special Tests and Provisions Repeat Finding: No Criteria: Federal regulations stipulate that Talent Search projects must deliver certain core services to eligible participants, including academic tutoring, course selection advising, college entrance exam prep, financial aid assistance, and guidance for GED or reentry programs. This requirement is codified in 34 CFR § 643.4. Additionally, applicable provisions in the OMB Compliance Supplement (2 CFR 200, Appendix XI, Part 4 – Department of Education: Special Tests and Provisions) require auditors to verify that all required services are provided to participants. Condition: During our test of controls and compliance with Special Tests and Provisions Services that Student Support Services, Talent Search, Upward Bound or McNair Projects Must Provide, we identified one participant who did not receive a required service—specifically, no academic tutoring or college entrance exam preparation was provided during the program year. Cause: Lack of internal controls over compliance—specifically, monitoring—did not allow the College to ensure all eligible participants received the required services • Case management or service delivery records were not consistently reviewed. • There was no verification step or supervisory review confirming service delivery before participant files were closed. Effect: By not delivering at least one mandated service to the participant: • The program falls into noncompliance with 34 CFR § 643.4, risking funding eligibility. • Potentially eligible students may not receive crucial educational support, which doesn’t align with the Talent Search’s objectives to improve college readiness and access. Questioned Cost: None. Context This issue was identified during a special test focusing on required services We tested a sample of 40 from a population of 1,369 students. Only one exception was found, suggesting this may not be systemic; however, even a single instance represents noncompliance with federal regulation. Recommendation: We recommend that Talent Search management: 1. Enhance monitoring controls and documentation—implement a checklist or sign-off process ensuring each required service is either recorded or formally declined in writing before participant case closure. 2. Conduct supervisory or quality assurance reviews—periodically (e.g., monthly), review a sample of participant files to confirm all mandated services have been delivered and properly documented, with corrective action taken when omissions are identified. Views of Responsible Officials: The College agrees with the recommendation and has provided a corrective action.

Finding 2025-002 – Time and Effort Documentation Type of Finding: Significant Deficiency and Compliance Federal Grant Name and ALN: TRIO Cluster: TRIO Educational Talent Search (84.044A) and TRIP Upward Bound (84.047A) Federal Agency: U.S. Department of Education (Grant ID P-044A210563-23 and P047A221356-24) Compliance Requirement: B. Allowable Costs/Costs Principles Repeat Finding: No Criteria: 2 CFR 200.430 (g)(vi) requires that charges to Federal Awards for salaries and wages be based on records that accurately reflect the work performed and that the records support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: The College complies with 2 CFR 430 (g)(vi) by requiring employees to complete time and effort form reflecting the employees’ duties within the grant. The forms are signed by the employees as well as a supervisor having firsthand knowledge of the employees’ duties. Two (2) forms from our sample of 40 were not signed when requested. Cause: Due to an administrative oversight, these forms were overlooked. Effect: Without completed time and effort forms, the College could risk unallowable employees to the TRIO Cluster. Questioned Cost: None. Context During our tests of federal payroll, we selected a sample of 40 from a population of 853. Two (2) employees from our sample did not have signed time and effort records until requested by the auditors. Recommendation: The College should review all charges, both planned and actual, against grant documents and time and effort forms to ensure that the planned expenditures conform to the grant application and that the actual charges are for employees working in the federal program. Views of Responsible Officials: The College agrees with the finding and recommendation and has prepared a corrective action plan.