Finding No.: 2021-012
Federal Agency: U.S. Department of Education
AL Program: 84.047A TRIO Upward Bound
Federal Award No.: P047A171556-21
Area: Eligibility
Questioned Costs: $24,646
Criteria: Per OMB Compliance Supplement July 2021, an individual is eligible to participate in a Regular UB project if the individual meets all of the following requirements:
(a) is a citizen, national, or permanent resident of the United States, or is in the United States for other than a temporary purpose;
(b) is a potential first-generation college student, a low-income individual, or an individual who has a high risk for academic failure;
(c) has a need for academic support in order to pursue successfully a program of education beyond high school; and
(d) at the time of initial selection has completed the 8th grade but has not entered the 12th grade and is at least 13 years old but not older than 19. A veteran, regardless of age, who meets all other criteria is eligible to participate.
A citizen, national, or permanent resident of the United States, includes a permanent resident of Guam, the Northern Mariana Islands, the Trust Territory of the Pacific Islands (Palau), or resident of one of the Freely Associated States - the Federated States of Micronesia or the Republic of the Marshall Islands.
Moreover, 34 CFR Part 645.6(b) defines “Individual who has a high risk for academic failure” as an individual who:
(a) Has not achieved at the proficient level on State assessments in reading or language arts;
(b) Has not achieved at the proficient level on State assessments in math;
(c) Has not successfully completed pre-algebra or algebra by the beginning of the tenth grade; or
(d) Has a grade point average of 2.5 or less (on a 4.0 scale) for the most recent school year for which grade point averages are available.
Furthermore, to be eligible for a stipend, participants must show evidence of satisfactory participation in project activities, including regular attendance and performance in accordance with the number of sessions in which a student participated. Stipends for regular projects may not exceed $40 per month from September to May of the academic year and $60 for each of the summer months (June, July, and August).
Moreover, 34 CFR Part 645.43(c) states that for each participant, a grantee must maintain a record of the basis for the grantee’s determination that the participant is eligible to participate in the project and the basis for the grantee’s determination that the participant has a need for academic support in order to pursue successfully a program of education beyond secondary school.
Condition: Of 9 students tested, aggregating $24,646 of $239,524 in total participant benefits, we noted noncompliance, as follows:
1. For 4 students listed below, no documentation was on file to support whether the individual is a citizen, national, or permanent resident of the United States (including a permanent resident of Guam, the Northern Mariana Islands, the Trust Territory of the Pacific Islands (Palau), or resident of one of the Freely Associated States - the Federated States of Micronesia or the Republic of the Marshall Islands), or is in the United States for other than a temporary purpose.
2. For 6 students listed below, it does not appear that the student has a need for academic support to successfully pursue a program of education beyond high school. Specifically, we noted that the student has either a) achieved at the proficient level on State assessments in reading or language arts; b) achieved at the proficient level on State assessments in math; c) successfully completed pre-algebra or algebra by the beginning of the tenth grade; or d) has a grade point average of higher than 2.5 (on a 4.0 scale) for the most recent school year. Further, we determined that the student does not have a high risk for academic failure, which is inconsistent with the College’s determined student eligibility status (“At high risk for academic failure”) reflected in the Annual Performance Report.
3. For 1 student (Student Case Number C000421734), it does not appear that the student has a need for academic support to successfully pursue a program of education beyond high school. Specifically, based on our examination of UB Program Recommendation Form accomplished by the student’s English and Math teachers, we noted that both teachers assigned the student a “B” grade (equivalent to 3.00 - 3.40 point in a 4.0 scale). Further, transcripts of records and/or State Assessments are not on file to support the College’s determined student eligibility status (“At high risk for academic failure”) reflected in the Annual Performance Report.
4. For 1 student (Student Case Number C000374322), no documentation was on file to support whether the individual has a need for academic support, to successfully pursue a program of education beyond high school. Further, transcripts of records and/or State Assessments are not on file to support the College’s determined student eligibility status (“At high risk for academic failure”) reflected in the Annual Performance Report.
5. For 3 students listed below, no documentation was on file to support whether the individual at the time of initial selection has completed the 8th grade but has not entered the 12th grade and is at least 13 years old but not older than 19.
Cause: The College lacks adequate internal control policies and procedures over eligibility determinations, including obtaining required documentation and verification to support the College’s determination that the participant is eligible to participate in the project.
Effect: The College is in noncompliance with applicable eligibility requirements. Accordingly, questioned costs of $24,646 result because the projected questioned costs exceed the $25,000 threshold.
Recommendation: College management should improve internal control policies and strengthen controls so that eligibility determinations, including obtaining required documentation and verification, are performed in accordance with applicable eligibility requirements.
Views of Auditee and Corrective Action Plan: The College agrees with the finding and provides details in its Corrective Action Plan.