FINDING 2025-001 Subject: TRIO Cluster - Eligibility Federal Agency: US Department of Education Federal Program: TRIO Talent Search Assistance Listings Number: 84.044 Federal Award Number and Year (or Other Identifying Number): P044A220683 Compliance Requirement: Eligibility Audit Findings: Significant Deficiency, Other Matters This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2024-002. Condition and Context An effective internal control system was not in place at the College to ensure compliance with the Eligibility compliance requirements. The following deficiencies over determination and noncompliance were noted: For TRIO Talent Search, 2 of the 16 students from the Northwest (Lake) Campus did not have evidence of internal controls over admission to the program. For TRIO Talent Search, 1 of the 16 students from the Northwest (Lake) Campus of the College could not provide evidence that the participant was a citizen, national, or permanent resident of the United States or in the United States for other than a temporary purpose. The lack of internal controls was isolated to the Northwest (Lake) Campus TRIO Talent Search program. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 34 CFR 646.3 states: "A student is eligible to participate in a Student Support Services project if the student meets all of the following requirements: INDIANA STATE BOARD OF ACCOUNTS 18 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Is a citizen or national of the United States or meets the residency requirements for Federal student financial assistance. (b) Is enrolled at the grantee institution or accepted for enrollment in the next academic term at that institution. (c) Has a need for academic support as determined by the grantee, in order to pursue successfully a postsecondary educational program. (d) Is– (1) A low-income individual; (2) A first generation college student; or (3) An individual with disabilities." Cause The College's management had not developed an effective system of internal controls that would have ensured compliance with the Eligibility compliance requirement. This was due to policies and procedures not being adequate to retain the documentation for TRIO Eligibility. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the Eligibility compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal controls procedures for federal programs are retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. INDIANA STATE BOARD OF ACCOUNTS 19
FINDING 2025-002 Subject: TRIO Cluster - Reporting Federal Agency: US Department of Education Federal Programs: TRIO Student Support Services, TRIO Talent Search, TRIO Upward Bound Assistance Listings Numbers: 84.042A, 84.044, 84.047 Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690, P042A201220, P042A201222, P044A220683, P047A221086, P047A221077 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2024-003. Condition and Context An effective internal control system was not in place at the College to ensure compliance with requirements related to the Reporting compliance requirement. The following errors on the fiscal year 2024 Annual Performance Report (APR) were noted: For TRIO Student Support Services at the Indianapolis Campus, key line items were tested for 24 students. For 1 student, field 31 "Undergraduate Degree/Certificate Completed at Grantee Institution" was inaccurately reported. For TRIO Student Support Services at the Northwest (Lake) Campus, key line items were tested for 22 students. o For 1 student, field 15 "Eligibility" was inaccurately reported. o For 2 students, field 18 "Date of First Project Service" was inaccurately reported. o For 1 student, field 19 "College Grade Level (entry into project)" was inaccurately reported. o For 7 students, field 23 "Enrollment Status (at end of academic year)" was inaccurately reported. o For 1 student, field 24 "Academic Standing" was inaccurately reported. o For 3 students, field 31 "Undergraduate Degree/Certificate Completed at Grantee Institution" was inaccurately reported. For TRIO Student Support Services at the Richmond Campus, key line items were tested for 25 students. o For 2 students, field 17 "First Enrollment Date (at grantee institution)" was inaccurately reported. INDIANA STATE BOARD OF ACCOUNTS 20 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) o For 1 student, field 22 "Participant Status (during academic year)" was inaccurately reported. o For 8 students, field 23 "Enrollment Status (at end of academic year)" was inaccurately reported. o For 1 student, field 27 "College Grade Level (at end of academic year)" was inaccurately reported. For TRIO Talent Search at the Northwest (Lake) Campus, key line items were tested for 40 students. o For 10 students, the College could not provide supporting documentation for item A1 "Persisted in school for the next academic year at the next grade level or graduated high school." o For 2 students, the College inaccurately reported that the students persisted in the next academic year at the next grade level; however, the students did not advance to the next grade level. For TRIO Upward Bound at the Indianapolis Campus, key line items were tested for 10 students. For 1 student, field 17 "Reading Language Arts or Math Proficiency Not Achieved" was inaccurately reported. For TRIO Upward Bound at the Muncie Campus, key line items were tested for 9 students. o For 3 students, field 16 "Eligibility" was inaccurately reported. o For 1 student, field 17 "Reading Language Arts or Math Proficiency Not Achieved" was inaccurately reported. o For 1 student, field 19 "Pre-Algebra or Algebra Course Not Successfully Completed by Beginning of 10th Grade" was inaccurately reported. The lack of effective internal controls and noncompliance was a systemic issue at four of the five campuses that were reported on the TRIO Cluster program during the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 21 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.329(c)(1) states in part: "The recipient or subrecipient must submit performance reports as required by the Federal award. . . ." 34 CFR 646.32(c) states in part: "Recordkeeping. A grantee must maintain participant records that show– (1) The basis for the grantee's determination that each participant is eligible to participate in the project under § 646.3; (2) The grantee's basis for determining the academic need for each participant; (3) The services that are provided to each participant; (4) The performance and progress of each participant by cohort for the duration of the participant's attendance at the grantee's institution . . ." Cause The College's management had not developed an effective system of internal controls that would have ensured compliance with the Reporting compliance requirement. The College had not developed policies and procedures to verify that the TRIO Cluster reporting agreed with supporting records. Effect Without the proper implementation of an effectively designed system of internal controls, the College cannot ensure reporting for the TRIO Cluster is accurate and in agreement with supporting records. Noncompliance with the reporting requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure reporting for the TRIO Cluster programs agree with supporting records of the College. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.