Finding 2025-009-U.S. Department of Education (ED) TRIO Cluster Programs (significant deficiency) Information on the federal program-Educational Talent Search, FAL 84.044A This memorandum serves as management’s response to the audit finding regarding internal control weaknesses in participant eligib...
Finding 2025-009-U.S. Department of Education (ED) TRIO Cluster Programs (significant deficiency) Information on the federal program-Educational Talent Search, FAL 84.044A This memorandum serves as management’s response to the audit finding regarding internal control weaknesses in participant eligibility documentation for the Educational Talent Search Program under 34 CFR § 643.3. Acknowledgment of Finding 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. Management Response During the initial application process, parent and student data is entered into a system-generated 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. Corrective Action Plan 1. Standardized Eligibility Verification Process A comprehensive eligibility checklist will be implemented and required for all participant files to ensure consistent documentation collection and verification prior to acceptance. Before an acceptance letter is provided to students, and the information is entered into Blumen, birthdates will be checked by the school transcript. Responsible Party: Assistant Director and Program Director Implementation Date: Immediately upon receiving the application 2. Secondary Review and Approval Control A mandatory secondary review process will continue. Participants’ acceptance will not be approved until all eligibility documentation is verified as accurate complete. Responsible Party: Assistant Director Accountable: Program Director Implementation Date: Immediate 3. Staff Training and Procedure Reinforcement All staff will participate in mandatory training on eligibility requirements and documentation standards. Written procedures and required intake documentation will be provided to reinforce compliance expectations. Responsible Party: Assistant Director and Program Director Accountable: Program Director Implementation Date: Monthly 4. Documentation Tracking System Management will implement a tracking procedure to identify and monitor missing or incomplete documentation, ensuring deficiencies are resolved prior to participant approval. Responsible Party: Assistant Director and Senior Counselors Accountable: Program Director Implementation Date: Immediately upon receiving the application 5. Ongoing Monitoring and Internal Reviews Quarterly internal file reviews will be conducted to assess compliance with eligibility requirements. Findings will be documented and corrective actions enforced. Responsible Party: Assistant Director and Senior Counselor Accountable : Program Director Implementation Date: Quarterly 6. Documentation Retention Controls Uniform file management protocols will be established to ensure all eligibility documentation is properly maintained, organized, and readily accessible. Responsible Party: Assistant Director Accountable Program: Director Implementation Date: Ongoing Conclusion Management takes this matter seriously and is committed to ensuring that all corrective actions are fully implemented within the stated timeframes. These measures are designed to strengthen internal controls, ensure compliance with federal requirements, and enhance the integrity of participant eligibility determinations. The College has already initiated corrective action by hiring entirely new staff in key positions and is committed to fostering a culture of compliance through rigorous procedures and training. 1. Staff Expertise: Financial Aid team members are becoming certified in the enterprise resource program module, specifically related to financial aid, as a first step. 2. SOP Implementation: The core of this plan involves the creation of seven new or updated Standard Operating Procedures (SOPs) (as highlighted above) to standardize compliance activities and reduce reliance on individual employee experience. 3. Proactive Monitoring: We are implementing mandatory monthly and quarterly reconciliation and audit reports to ensure adherence to timelines and documentation requirements, moving from reactive to proactive compliance management. 4. Cross-Training: Training will be conducted across multiple departments (Financial Aid, Business Office, Registrar) to ensure shared understanding and accountability for Title IV compliance.