Audit 407034

2025-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Education ALN: 84.047 Criteria Per 34 CFR 644.32(a)(1), grantees shall determine the eligibility of each participant in the project at the time the individual is selected to participate. Per 34 CFR 644.32(c), grantees must also maintain a record of how the grantee determined that the participant was eligible to participate in the program under 34 CFR 644.3. Condition During our testing of 40 Educational Opportunity Centers ("EOC") participants, we found that MDC enrolled 4 individuals who had incomplete program information. We noted that each individual had left portions of the enrollment form blank. MDC was unable to produce any follow-up communication with the program participant to verify eligibility before they were enrolled in the program. As a result, MDC was unable to support all participants enrolled in EOC met the program eligibility requirements. Questioned costs Not determinable. Cause MDC lacked sufficient internal control over the review process of enrollment forms to ensure participants were eligible to be enrolled in EOC. Effect MDC’s failure to properly review and verify individual’s eligibility could result in services being provided to participants who do not meet the EOC eligibility requirements. Recommendation We recommend that MDC design and implement adequate internal control over its eligibility intake and determination process. MDC should require a program manager to verify a participant’s intake form for eligibility requirements, prior to enrolling them in its programs. MDC should also develop a protocol for how employees can respond and resolve incomplete enrollment forms. Training should be provided to all staff responsible for reviewing program eligibility forms.

2025-002 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Education ALN: 84.047 Criteria Per 34 CFR 643.11(b) and 645.21(a)(4) require Talent Search and Upward Bound projects to collaborate with other TRIO, GEAR UP (ALN 84.334), or similar programs serving the same target population to minimize duplication of services. Additionally, 34 CFR 643.32(c)(5) and 645.43(c)(5) require the grantees to maintain records (to the extent practicable) of services participants receive from other federally funded programs serving similar populations. Condition During our review of the special tests and provisions and eligibility for Upward Bound, we noted that MDC asks potential program participants on its intake form if they are enrolled in any other Upward Bound or Talent Search programs, presumably to ensure there is collaboration with the local programs to mitigate duplication of services. We noted that 9 program participants indicated they were enrolled in other local programs on their intake form. MDC was unable to provide evidence of collaboration with the other programs the students were enrolled in, and records in the participant file of services the participants are receiving from other TRIO programs. Questioned costs Not determinable. Cause MDC lacked sufficient internal control over compliance with collaboration and documentation requirements. MDC does not appear to conduct any follow-up with the other Upward Bound and Talent Search program(s) that the student is enrolled in, prior to enrolling them in MDC’s Upward Bound program. There does not appear to be any protocol to coordinate with other programs to avoid service overlap. Effect MDC’s lack of documentation and coordination efforts with local Upward Bound and Talent Search programs increases the risk of duplication of services for program participants. This may result in inefficient use or unreasonable costs of Federal award funds. Recommendation We recommend that MDC design and implement adequate controls over its coordination efforts with local Talent Search and Upward Bound programs to mitigate duplication of services with its program participants. There should be a tracking mechanism implemented that records services provided to participants from other Department of Education programs. Training should be provided to staff on how to adequately respond when a program participant attests to receiving services from other Department of Education programs. MDC should document its collaboration efforts with other Upward Bound and Talent Search programs to mitigate duplication of services, in each program participant’s file who attests to being enrolled in other programs.