Finding No.: 2022-017 Federal Agency: U.S. Department of Education AL Program: 84.047A TRIO Upward Bound Federal Award No.: P047A171556-21 Area: Eligibility Questioned Costs: $54,380 Criteria: Per OMB Compliance Supplement April 2022, an individual is eligible to participate in a Regular Upward Bound 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). 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. 2 CFR 200.303(a) states that the subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the COSO. Conditions: Of 17 students tested, aggregating $54,380 of $208,665 in total participant benefits, we noted noncompliance, as follows: 1. For 1 student (Student Case Number C000421743), 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 the 17 students listed below, no documentation on file to support the basis for the grantee’s determination that the participant has a need for academic support to successfully pursue a program of education beyond secondary school. Item # Student Case Number 1 C000303202 2 C000374298 3 C000421743 4 C000421735 5 C000374297 6 C000374309 7 C000374311 8 C000421736 9 C000374317 10 C000303229 11 C000374318 12 C000374321 13 C000421746 14 C000421747 15 C000401854 16 C000374325 17 C000303220 3. For the 4 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. Item # Student Case Number 1 C000374298 2 C000421743 3 C000374317 4 C000374321 4. For the 2 students listed below, no documentation was on file to support whether the individual is a potential first- generation college student, a low-income individual, or an individual who has a high risk for academic failure. Item # Student Case Number 1 C000374298 2 C000374297 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 not in compliance with the applicable eligibility requirements. The total questioned cost is $54,380. Identified as a Repeat Finding: 2021-012 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 the applicable eligibility requirements. Views of Auditee and Planned Corrective Actions: The College agrees with the finding and provides details in its Corrective Action Plan.