II. Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material
weakness):
We observed the following conditions in connection with our testing of the TRIO programs:
(a) UB Eligibility Test: Of the 17 students selected for testing, one (1) student’s citizenship could
not b...
II. Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material
weakness):
We observed the following conditions in connection with our testing of the TRIO programs:
(a) UB Eligibility Test: Of the 17 students selected for testing, one (1) student’s citizenship could
not be determined, two (2) students did not provide any income information on the
application, ten (10) students did not provide tax returns to verify low income as reported.
(b) ETS Eligibility Test: Of the 17 students selected for testing, seven (7) students' citizenship
status could not be determined, documentation to support enrollment status was not
provided for 17 students, one (1) student did not have any information uploaded, and one (1)
student has a birthdate discrepancy.
(c) Educational Opportunity Center (EOC) Eligibility Test: Of the 17 participants selected for EOC
testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents
uploaded to adequately test the attributes, and one (1) student did not have a signature page
for the EOC application.
Auditor's Recommendation – We recommend the College ensure that all required documentation
is submitted prior to determining the participants' eligibility.
Corrective Action – Tougaloo College Administration understands the importance of federal
compliance. The Vice President for Strategic Initiatives & Social Justice has direct management
oversight of the TRIO programs. The lack of internal controls related to UB Eligibility Test, ETS
Eligibility Test, and EOC Eligibility Test (verification of citizenship, income information, tax
refunds, documentation of enrollment status, enrollment agreement, and birthdate
verification), a non-recurring finding, were largely caused by a high degree of staff turnover
and lack of experience in the front-line staff directly responsible for these controls. Although it
has proven difficult to hire and retain highly qualified staff due to higher salaries paid by other
institutions for similar positions in our market, the Executive Director of the TRIO programs and
leadership team has implemented the following actions to correct the findings:
1. Continue to recruit and develop internal protocols to more fully retain highly qualified
personnel.
2. Continue to train staff and increase staff training specific to reviewing the proper
documentation required for attending the programs.
3. Include an additional level of early review by the Executive Director and other senior
program staff to verify compliance at multiple stages of program involvement by students,
including when students are initially recruited and enrolled.
4. Internal federal compliance testing will be a required criteria for the staff annual
evaluations reviewed by the Executive Director of TRIO programs and the Vice President for
Strategic Initiatives & Social Justice.