Finding 2025-001 - U.S. Department of Education (ED), Student Financial Assistance Programs – Satisfactory Academic Progress (material weakness): Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025 Criteria – An institution must establish a reasonable satisfactory academic progress policy for determining whether an otherwise eligible student is making satisfactory academic progress in his or her educational program and may receive assistance under the Title IV, HEA programs. 34 CFR 668.34. Condition – We observed that 16 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the Fall and Spring semesters. The College did not provide supporting documentation for successful appeals and allowed the students to receive Title IV student financial assistance funding. Cause – SAP was not properly monitored during the semester by responsible persons. This appears to have been an oversight. Effect – Ineligible students may have received Title IV federal student financial assistance funds. Questioned Costs – $346,764. Perspective – This is considered a systemic problem given the 16 exceptions noted from the sample of 60 students. Repeat Finding – Yes. Auditor's Recommendation – The College should evaluate all students at least annually to ensure they meet satisfactory academic progress. The frequency of the evaluation should be consistent with approved policies and procedures. This prevents ineligible students from possibly receiving Title IV federal student financial aid. Management’s Response – Tougaloo College acknowledges the findings identified in the audit for the fiscal year ending June 30, 2025, regarding Finding 2025-001 (Material Weakness). We recognize the gravity of the systemic issues related to the monitoring of Satisfactory Academic Progress (SAP) and the associated questioned costs of $346,764.00. The College is committed to full compliance with 34 CFR 668.34 and is implementing the following corrective actions to ensure the integrity of our Title IV Student Financial Aid Programs. • Automation and System Integration: The College is transitioning from manual SAP monitoring to an automated tracking system within our Student Information System (SIS). This will ensure that academic standing—specifically GPA and completion rates are calculated systematically at the end of each payment period. • Audit of Appeal Documentation: We are establishing a centralized digital repository for all SAP appeals. Effective immediately, no Title IV funds will be disbursed to students on financial aid probation without a documented, approved appeal and a corresponding academic plan on file. • Staff Training and Accountability: The Office of Financial Aid will undergo mandatory training focused specifically on federal SAP criteria. We have revised our internal "Check and Balance" protocol, requiring a secondary review by the Director of Financial Aid before any student failing SAP is cleared for disbursement. • Annual Policy Review: In alignment with the Auditor’s Recommendation, Tougaloo College will conduct a comprehensive annual evaluation of all students. This evaluation will be reconciled against the Registrar’s records to ensure data consistency. • We have updated our SAP policy to allow us to review at end of each Spring . The College has already begun the look-back process to review the eligibility of the 16 students identified in the sample. We anticipate that the new automated monitoring and revised internal controls will be fully operational by the start of the Spring 2026 semester to prevent any further repeat findings. View of Responsible Officials – The College agrees with the finding.
Finding 2025-002 - U.S. Department of Education (ED), Student Financial Assistance Programs – Federal Work-Study Program (material weakness): Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025 Criteria – Regardless of who employs the student, the institution is responsible for ensuring that the student is paid for work performed. 34 CFR 675.16. Condition – We are unable to verify the funds earned because five (5) of the six (6) students tested for Federal Work-Study Program payroll had missing and/or incomplete timesheets. Cause – The College did not properly review timesheets and either failed to obtain or misplaced timesheets documenting the hours worked to support compensation paid to students under the Federal Work-Study Program. One (1) student had a pay rate change but no documentation to support the change. Students worked when they were supposed to be in class. One (1) student signature & date is after starting date of employment. Effect – Students may have been over or underpaid compensation based on hours actually worked. Questioned Costs – $10,830. Perspective – This is considered a systemic problem given the five (5) exceptions noted from the sample of 6 students. Repeat Finding – Yes. Auditor's Recommendation – All timesheets should be reviewed and approved by the direct supervisor overseeing the student’s work before any Federal Work-Study wages are disbursed. Approved timesheets should then be systematically organized and securely retained to document compliance with federal requirements. Management’s Response – Tougaloo College acknowledges the findings identified in the audit regarding the Federal Work-Study (FWS) Program for the period ending June 30, 2025. We recognize the gravity of the "material weakness" designation and the systemic nature of the documentation exceptions noted. As the Vice President overseeing these services, I am committed to a rigorous overhaul of our FWS administrative protocols to ensure full compliance with 34 CFR 675.16. To address the root causes of these findings, the College is implementing the following measures immediately: • Mandatory Supervisor Training: All department heads and direct supervisors of FWS students must complete a mandatory compliance seminar. This training emphasizes that no student may be scheduled to work during designated class times and that no wages will be disbursed without a verified, contemporaneous timesheet. • Enhanced Timesheet Verification: We are transitioning to a standardized digital submission process. This system will require: o Verification of the student’s course schedule against hours worked to prevent overlap. o Electronic signatures from both the student and supervisor, timestamped to ensure they are captured prior to payroll processing. • Documentation and Record Retention: The Office of Financial Aid, in coordination with Payroll, will implement a "No Document, No Pay" policy. Documentation for any pay rate changes must now be uploaded and approved by the VP for Enrollment Management and Student Services before being reflected in the Jenzabar system. • Internal Monthly Audits: Starting next month, our internal compliance team will conduct random monthly spot-checks of FWS files (10% of active participants) to ensure all timesheets are present, complete, and accurately reflect hours worked. The College is currently reviewing the identified questioned costs of $10,830.00. We will work closely with the U.S. Department of Education to determine the appropriate restitution or adjustment required for any overpayments resulting from missing documentation. We are dedicated to rectifying these systemic issues and ensuring this does not remain a repeat finding in future audit cycles. Our goal is to maintain the highest level of integrity in our Title IV Student Financial Aid Programs. View of Responsible Officials – The College agrees with the finding.
Finding 2025-003 - U.S. Department of Education (ED), Student Financial Assistance Programs – Withdrawals & Return of Title IV Funds (material weakness): Information on the federal program –Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025 Criteria – The institution must determine the portion of aid the student earned and the portion that is unearned at the time of withdrawal. Any unearned portion of Title IV funds must be returned to the U.S. Department of Education as soon as possible but no later than within 45 days after the confirmed date of withdrawal. HEA, Section 484B & 34 CFR 668.22. Condition – We observed that two (2) of the four (4) students tested had incorrect calculations. One (1) was completed late and one (1) used the incorrect calendar dates. Cause – The College did not adequately track student withdrawals during the year, particularly those students who unofficially withdrew. Effect – ED may assess liabilities or require reimbursement of funds. Further, federal funding could be reduced or the College placed on heightened cash monitoring. Questioned Costs – $13,100. Perspective – This is considered a systemic problem given the two (2) exceptions noted. Repeat Finding – No. Auditor's Recommendation – The College must strengthen its procedures for monitoring and documenting student withdrawals by consistently adhering to its established policies. This applies to both official and unofficial withdrawals to ensure accurate identification of withdrawal dates and the timely calculation and return of Title IV funds in accordance with federal regulations. Management’s Response – The Office of Enrollment Management and Student Services accept the auditor’s findings regarding the administration of Title IV funds and the Return of Title IV (R2T4) calculations. We recognize that the accurate tracking of student withdrawals—particularly unofficial withdrawals—is critical to maintaining federal compliance and institutional integrity. While this was not a repeat finding, we view the "systemic" nature of the observation with the utmost seriousness. The College is committed to rectifying the procedural gaps that led to incorrect calculations and late submissions. To address the Cause identified (inadequate tracking) and mitigate the Effect of potential liabilities, the following measures are being implemented immediately: • Enhanced Tracking for Unofficial Withdrawals: The Registrar’s Office, in coordination with Information Technology (IT), will implement a bi-weekly "Internal Attendance & Participation" audit. This automated report will flag students with zero academic engagement across all registered courses, allowing the Financial Aid office to identify unofficial withdrawals well before the 45-day federal deadline. • Standardization of Calendar Dates: The Director of Financial Aid has revised the R2T4 calculation worksheet to include a "Mandatory Calendar Verification" step. This ensures that the start/end dates and scheduled breaks used in calculations strictly align with the approved institutional academic calendar. • Staff Training and Capacity Building: All Financial Aid staff responsible for R2T4 calculations will undergo mandatory Title IV compliance training. Furthermore, a secondary review process has been established where a senior staff member must sign off on all calculations exceeding $1,000 to ensure accuracy before funds are returned. View of Responsible Officials – The College agrees with the finding.
Finding 2025-004 - U.S. Department of Education (ED), Student Financial Assistance Programs – Cost of Attendance Budgets (material weakness): Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025 Criteria – Institutions must determine a student’s financial need by subtracting the student aid index (expected family contribution) and estimated financial assistance from the cost of attendance. 34 CFR 668.2 and 34 CFR 637.5(a). Condition – The College did not provide Cost of Attendance (COA) budgets to determine students’ unmet need. Cause – The condition occurred because the College lacked adequate internal controls and documented procedures to ensure that COA budgets were consistently established, retained, and applied during financial aid packaging. Effect – There is a risk of over-awards or improper disbursements of federal funds to ineligible students which could result in repayment liabilities. Questioned Costs – Unknown. Perspective – This is considered a systemic problem since the College was unable to produce the COA budget for the academic year. We observed the following conditions in connection with our testing of the various U.S. Department of Education, Student Financial Assistance Programs. Sixty (60) out of 60 students tested for cost of attendance budgets couldn’t be verified. Repeat Finding – Yes. Auditor's Recommendation – Internal controls should be strengthened or implemented to ensure a COA budget is established annually and need is calculated for each student to avoid noncompliance with federal regulations. A periodic review of the COA budget should be done to verify. Management’s Response – The College concurs with this finding. We acknowledge that the absence of documented Cost of Attendance (COA) budgets and the resulting inability to verify financial need calculations constitute a significant breakdown in internal controls. The College is committed to immediate remediation to ensure full compliance with Title IV regulations. To address the root causes of this finding, the College will implement the following measures: • Establishment of Formal COA Budgets: The Financial Aid Office will immediately develop and document standardized COA budgets for the 2025-2026 academic year. These budgets will account for all required components (tuition, fees, housing, food, books, supplies, transportation, and personal expenses) as required by 34 CFR 668.2. • System Integration: We will update our Student Information System (SIS) to automate the application of these COA budgets to student records, ensuring that "Unmet Need" is calculated electronically and consistently for every applicant. • Formalized Internal Controls: A new Standard Operating Procedure (SOP) manual for Financial Aid Packaging will be authored and implemented by June 1, 2026. This manual will mandate the retention of COA tables used for each award year to provide a clear audit trail. • Enhanced Oversight and Training: The Vice President for Enrollment Management and Student Services will initiate a mandatory training program for all financial aid staff regarding federal packaging requirements. • Internal Quality Assurance (IQA): Beginning April 15, 2026 the College will implement a monthly "Mini-Audit" process where a random sample of 10% of student files is reviewed by a third-party or a non-conflicted administrator to verify COA accuracy before disbursements are finalized. Designated Responsible Party-Director of Financial Aid. Anticipated Completion Date-June 30, 2026 View of Responsible Officials – The College agrees with the finding.
Finding 2025-005 - U.S. Department of Education (ED), Student Financial Assistance Programs – Fiscal Operations Report and Application to Participate (FISAP) (material weakness): Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025 Criteria – Institutions must maintain records supporting the accuracy of FISAP data. 34 CFR 675.19(b)(3) and 34 CFR 676.19(b). Condition – The Office of Financial Aid submitted invalid information within the Fiscal Operations Report and Application to Participate (FISAP) for Part 2, Section F: Information on Eligible Aid Applicants enrolled in school for award year 2024-2025. Cause – The College did not utilize the FISAP reports from the Jenzabar FA/SIS to complete the report. Effect – Errors or inaccuracies in FISAP reporting can cause the ED to misallocate campusbased program funds in future award years, which may result in the institution being required to return over-awarded funds and could affect future funding eligibility. Questioned Costs – Unknown. Perspective – This is considered a systemic problem as it appears a system update may not have been installed for proper reporting Repeat Finding – No. Auditor's Recommendation – The Student Financial Aid Office & Information Technology Department should ensure that all system updates are completed timely. This will enhance the accuracy of data submitted on the FISAP. Management’s Response – The Office of Enrollment Management and Student Services acknowledge the auditor’s finding regarding the discrepancies in the Fiscal Operations Report and Application to Participate (FISAP) for the 2024-25 award year. We recognize the criticality of maintaining accurate records to support federal funding eligibility and are committed to resolving the underlying systemic issues identified. The College concurs with the finding. It was determined that the inaccuracies in Part 2, Section F (Information on Eligible Aid Applicants) resulted from a lack of synchronization between the latest federal reporting requirements and the institution’s current software version. Specifically, the manual compilation of data was used in lieu of automated Jenzabar reports due to a pending system update. To ensure future compliance and the accuracy of all Title IV reporting, the following actions have been initiated: • System Synchronization & Updates: The Information Technology (IT) Department, in coordination with the Office of Financial Aid, has established a priority schedule for all Jenzabar FA/SIS system updates. A mandatory "Systems Readiness" review will now occur 60 days prior to the FISAP submission deadline to ensure all regulatory patches are installed. • Standardization of Reporting Procedures: Management has mandated that all future FISAP data must be pulled directly from the Jenzabar system modules. Manual entries will only be permitted as a secondary verification measure to ensure data integrity against system-generated reports. • Inter-Departmental Oversight: A new "FISAP Task Force" comprising representatives from Financial Aid, IT, and Business/Finance has been formed. This group will perform a preliminary review of the FISAP data 30 days before submission to verify that the system-generated data aligns with institutional records and federal criteria (34 CFR 675.19 and 34 CFR 676.19). • Technical Assistance Engagement: The College is currently coordinating with the U.S. Department of Education to facilitate an On-site Title IV Technical Assistance & Support (OTA) visit. This visit will include a specific focus on optimizing our SIS reporting capabilities for campus-based program funds. Implementation Timeline • System Update Completion: Immediate (April 2026) • Standard Operating Procedure (SOP) Revision: May 15, 2026 • On-site Technical Assistance Visit: Expected April/May 2026 View of Responsible Officials – The College agrees with the finding.
Finding 2025-006 - U.S. Department of Education (ED), Student Financial Assistance Programs – Federal Work-Study Community Service (material weakness): Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025 Criteria – Institutions are required to employ students in community service jobs annually and utilize 7% of the allocation. 34 CFR 675.18. Condition – The institution did not provide a list of community service participants for the 2024- 2025 academic year. Therefore, we were unable to verify institutional compliance. Cause – It appears the Student Financial Aid Office hasn’t employed any students in this area for 2024-2025. Effect – It appears the Student Financial Aid Office hasn’t employed any students in this area for 2024-2025. Questioned Costs – $16,500. Perspective – This is considered a systemic problem given no students were placed in FWS Community Service jobs throughout the academic year. Repeat Finding – No. Auditor's Recommendation – Internal controls should be strengthened or implemented to ensure that students are employed in community service jobs annually. Management’s Response – Tougaloo College acknowledges the auditor’s finding regarding the 7% Federal Work-Study (FWS) community service expenditure requirement under 34 CFR 675.18. While the College has a storied history of community engagement, we recognize that the administrative tracking and placement of students into qualifying FWS community service positions for the 2024-25 academic year did not meet federal mandates. Management accepts the recommendation to strengthen internal controls and is committed to ensuring that our Student Financial Aid Office has the oversight necessary to maintain compliance and protect our participation in Title IV programs. Corrective Action Plan (CAP): • Expanded Community Partnerships: The Office of Enrollment Management and Student Services will immediately re-establish and formalize Memorandums of Understanding (MOUs) with local non-profit organizations and governmental agencies in the Jackson, MS metropolitan area. These partnerships will prioritize literacy and mathematics tutoring (consistent with the FWS "America Reads/America Counts" initiatives) and social service support. • Enhanced Internal Monitoring: The Director of Student Financial Aid will implement a monthly FWS Allocation Tracker. This internal control will monitor FWS expenditures specifically for community service to ensure the 7% threshold is reached well before the end of the academic year. • Administrative Oversight: The Vice President for Enrollment Management and Student Services will conduct a formal quarterly review of these trackers. This ensures that any shortfall in community service placements is identified early enough to initiate a Community Service Waiver request to the U.S. Department of Education, should unique circumstances arise. • Student Awareness Campaign: We will integrate community service FWS opportunities into our student orientation and "Federal Work-Study Fair" to ensure students are aware of these high-impact service opportunities. Completion Date: August 15, 2026 View of Responsible Officials – The College agrees with the finding.
Finding 2025-007 - U.S. Department of Education (ED), Student Financial Assistance Programs – Policy & Procedures Manual (material weakness): Information on the federal program – Major Programs: Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025 Criteria – Institutions are required to have a current Financial Aid Policy & Procedures Manual to ensure that staff are processing financial aid correctly and in a manner that complies with the Department of Education. CFR 668.34. Condition – We received a 2018-19 copy of the Policy and Procedure Manual, but it was outdated. Cause – This manual has not been updated in over five years. Effect – Not having an updated manual could lead to incorrect processing to student financial assistance funding and not in compliance with transparency requirement. Questioned Costs – $0 Perspective – This is considered a systemic problem given this document is very outdated. Repeat Finding – No. Auditor's Recommendation – The Student Financial Aid Office should update the Policy & Procedures Manual to ensure it meets the current requirements of the Department of Education. Management’s Response – The Office of the Vice President for Enrollment Management and Student Services concurs with this finding. We recognize that the maintenance of a current and comprehensive Policy & Procedures Manual is a fundamental requirement under 34 CFR 668.16 and 34 CFR 668.34 to ensure the consistent and accurate administration of Title IV federal student aid. While the institution maintained operational compliance with Department of Education regulations throughout the audit period, we acknowledge that the formal documentation had not been updated since the 2018-2019 academic year. To address this finding and mitigate any risk of systemic processing errors, the Student Financial Aid Office has completed a comprehensive revision of the Financial Aid Policy & Procedures Manual. • Completion Status: The manual has been fully updated to reflect the 2024- 2026 academic cycles. • Scope: The updated manual incorporates current federal regulations for all major programs, including the Federal Pell Grant, FSEOG, Federal Work-Study, Federal Direct Student Loans, and TEACH Grant programs. • Compliance: The new documentation aligns with the latest Federal Student Aid Handbook guidance and ensures that all institutional policies meet current USDE requirements. To ensure this remains a "one-time" finding rather than a recurring issue, the Financial Aid Director has implemented an Annual Review Protocol. Beginning in June of each year, the manual will undergo a formal review and update cycle to coincide with the release of the new award year’s federal guidelines. View of Responsible Officials – The College agrees with the finding.
Finding 2025-008 - U.S. Department of Education (ED), Student Financial Assistance Programs - NSLDS Enrollment (material weakness): Information on the federal program – Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025 Criteria – The withdrawal status must be verified for withdrawn students. NSLDS Enrollment Maintenance 34 CFR 685.309(b), 682.610(c), 674.33(j). Condition – We observed that two (2) of the four (4) students tested were not in compliance with Enrollment Reporting. One (1) of the students did not have the withdrawn status reported. Cause – Timely reporting of withdrawn students is required throughout the award year. Effect – Not reporting withdrawal statuses timely affects the repayment of student loans. Questioned Costs – Unknown. Perspective – This is considered a systemic problem given the two (2) exceptions noted. Repeat Finding – No. Auditor's Recommendation – The institution must provide the NSLDS enrollment information for withdrawn students for the academic year and ensure enrollment status changes are reported within the regulatory timeline. Management’s Response – Management concurs with Finding 2025-008 related to NSLDS Enrollment Reporting for withdrawn students. The institution acknowledges that one (1) withdrawn student was not reported timely to NSLDS during the period tested, resulting in two (2) of the four (4) students reviewed not being in full compliance with federal enrollment reporting requirements under 34 CFR 685.309(b), 682.610(c), and 674.33(j). Upon identification of the issue, the institution conducted a review of enrollment reporting processes to confirm the nature of the error. Management determined that the exception resulted from a breakdown in communication between the Registrar’s Office and the Financial Aid Office regarding withdrawal notifications during the award year. Corrective actions have been initiated and include the following: • All previously unreported or incorrectly reported withdrawal statuses for the academic year have been reviewed and submitted to NSLDS. • Enrollment reporting procedures have been updated to formalize coordination between the Registrar’s Office and Financial Aid to ensure timely identification and reporting of enrollment status changes. • A secondary review process has been implemented prior to NSLDS submission to verify withdrawn student statuses. • Staff responsible for enrollment reporting have received refresher training on NSLDS requirements and regulatory timelines. Management expects these corrective actions to strengthen internal controls over enrollment reporting and ensure compliance with federal regulations moving forward. View of Responsible Officials – The College agrees with the finding. Responsible officials acknowledge the seriousness of this finding and recognize that timely and accurate NSLDS enrollment reporting is critical to the integrity of Title IV programs and the proper administration of student loan repayment obligations. The institution is committed to maintaining compliance with all federal student aid requirements and agrees that this issue represents a control weakness that required immediate attention. While the error affected a limited number of students, officials understand the potential systemic implications and have taken corrective measures accordingly. Responsible officials will continue to monitor enrollment reporting through periodic reconciliations and management oversight to ensure all enrollment status changes—including withdrawals—are reported accurately and within the prescribed regulatory timeframe. Management believes the corrective actions implemented will prevent recurrence of this issue and demonstrate the institution’s commitment to compliance and accountability.
Finding 2025-009 - U.S. Department of Education (ED) TRIO Cluster Programs (significant deficiency): Information on the federal program – Educational Talent Search, FAL No. 84.044A Criteria – Federal regulation 34 CFR § 643.3 establishes eligibility requirements for the TRIO Talent Search program mandates that participants must be aged 11–27, have completed the 5th grade, and be enrolled in or dropped out of middle/high school or be pursuing postsecondary education. Participants must be U.S. citizens or eligible residents, and at least 66% must be both low-income and potential first-generation college students. Grant recipients must maintain verifiable documentation supporting each participant’s eligibility status before acceptance into the program. Condition – Based on the test of participants for Educational Talent Search, two (2) out of eleven (11) participant files contained birth discrepancies or unclear age documentation preventing verification that the participants met the program’s required age criteria. As a result, participant eligibility could not be substantiated for these individuals. Cause – This issue occurred due to insufficient internal controls within the participant intake and eligibility verification process. Staff did not consistently follow established procedures for collecting, reviewing, and retaining required eligibility documentation. Additionally, no secondary review or supervisory oversight existed to confirm that age and enrollment documentation were complete prior to approving participant intake. The current filing and records management system also lacks a mechanism to clearly track missing or incomplete eligibility documents, contributing to the oversight. Effect – Failure to collect and maintain proper eligibility documentation results in noncompliance with federal regulations 34 CFR § 643.3 and TRIO program requirements, increased risk of serving ineligible participants, which can compromise the program’s required demographic composition, potential questioned costs for participants whose eligibility cannot be substantiated and possible negative impact on future TRIO funding. Question Cost – $0 Perspective – The issue represents a systemic control weakness, as 18% of participant files tested failed to include adequate documentation verifying eligibility criteria. The condition appears to reflect a widespread and recurring issue rather than an isolated oversight indicating that improvements are necessary in documentation collection, verification and recordkeeping procedures. Repeat finding – No Auditor’s recommendation – We recommend that the TRIO Director ensure that all eligibility requirements are fully documented and verified prior to accepting participants into the program. This should include implementing a standardized eligibility checklist for each participant file, conducting training for staff responsible for intake and documentation; establishing a secondary review or supervisory approval process prior to finalizing participant acceptance; and enhancing the recordkeeping system to track and flag missing documents. Management’s Response – Management acknowledges the condition identified in which two participants’ applications lacked incorrect information to verify age eligibility requirements. Management notes, this condition reflects a perceived control weakness that may impact compliance with TRIO Talent Search Program requirements. During the initial application process, parent and student data is entered into a systemgenerated application. Management acknowledges that, in instances where inaccurate information is entered (e.g., date of birth), established procedures require verification against official documentation, such as the student’s transcript. Supporting documentation for Shayla Adams and Madison Wallace is provided as evidence. Upon identifying omissions or incorrect information during the review process, management verifies the applicants’ information directly with the participants’ school as part of the secondary review process. Official documentation is obtained and reviewed, and the verified date of birth is recorded as documented on the students’ official transcripts and maintained in the participant files. The applicants’ information is entered correctly in the student database (Blumen) prior to acceptance, ensuring compliance with eligibility documentation requirements under 34 CFR § 643.3. Management is committed to addressing this issue promptly and strengthening internal controls to ensure full compliance with federal regulations. Procedures governing participant intake, eligibility verification, documentation retention, and supervisory oversight will be consistently monitored. These measures include standardized processes, increased staff accountability, and ongoing monitoring to maintain program integrity. View of responsible official – The College agrees with the finding.