Finding 1160136 (2022-018)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2025-10-06
Audit: 370531
Organization: College of the Marshall Islands (MH)

AI Summary

  • Core Issue: The College failed to provide key documentation for the Annual and Final Performance Reports during the audit.
  • Impacted Requirements: Noncompliance with OMB guidelines and federal reporting requirements due to inadequate internal controls over documentation.
  • Recommended Follow-Up: Strengthen internal controls to ensure all required reports and supporting records are retained for compliance.

Finding Text

Finding No.: 2022-018 Federal Agency: U.S. Department of Education AL Program: 84.047A TRIO Upward Bound Federal Award No.: P047A171556-21 Area: Reporting Questioned Costs: $0 Criteria: Performance Reporting - Per OMB Compliance Supplement Addendum April 2022, grantees must submit an annual performance report to ED each year of the project period. The following line items contain critical information: Section II, Record Structure for Participant List for Upward Bound and Upward Bound Math- Science Projects, fields: 16 Eligibility (at time of initial selection) 17 At Risk: Reading Language Arts or Math Proficiency Not Achieved (at time of initial selection) 18 At Risk: Low Grade Point Average (at time of initial selection) 19 At Risk: Pre-Algebra or Algebra Course Not Successfully Completed by Beginning of 10th Grade (at time of initial selection) 20 Limited English Proficiency (at time of initial selection) 24 Date of First Project Service 25 Grade Level at First Service 27 Participant Status for reporting year 28 Participation Level for reporting year 29 Served by Another Federally Funded College Access Program for reporting year 30 Grade Level at the beginning of academic year being reported 37 Secondary School Retention and Graduation Objective – Numerator, for reporting year 45 Date of Last Project Service In addition, under the terms of the grant award, all recipients are required to submit a final performance report within 120 days after the expiration or termination of grant support. Furthermore, 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: 1. Section II of the Annual Performance Report which pertains to source data file could not be provided during the audit. 2. Final Performance Report could not be provided during the audit. Cause: The College lacks adequate internal controls over compliance with the applicable federal regulations relating to reporting, specifically, retaining sufficient documentation to support reported information. Effect: The College appears to be in noncompliance with the applicable reporting requirements. No questioned cost is presented as we are unable to quantify the extent of noncompliance. Recommendation: College management should strengthen controls so that required reports and supporting records are retained to evidence compliance with the applicable reporting requirements. Views of Auditee and Planned Corrective Actions: The College agrees with the finding and provides details in its Corrective Action Plan.

Corrective Action Plan

Reporting College of the Marshall Islands acknowledges the finding and agrees that both the Section II source data file of the Annual Performance Report (APR) and the required Final Performance Report could not be provided during the audit. This occurred due to inadequate internal controls and the limitations of the previous manual filing system, which led to incomplete retention and difficulty retrieving submitted reports during the audit fieldwork. To correct this, the College has upgraded and institutionalized a cloud-based filing system to ensure all source data files, APR submissions, and Final Performance Reports are properly stored, organized, and easily accessible. Internal control policies and procedures have been strengthened to require that all performance reports are submitted on time, with verified source data and confirmation of successful submission retained in the system. The TRIO Office has established a reporting calendar, supervisory review process, and digital archive protocol to ensure all APR and final reports are prepared, submitted, and properly retained. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to meet federal reporting requirements. Staff have been trained— and will continue to be trained twice a year—on performance reporting procedures and federal reporting standards to prevent recurrence of similar issues in future audits.

Categories

Subrecipient Monitoring Eligibility Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1160126 2022-008
    Material Weakness Repeat
  • 1160127 2022-009
    Material Weakness Repeat
  • 1160128 2022-010
    Material Weakness Repeat
  • 1160129 2022-011
    Material Weakness Repeat
  • 1160130 2022-012
    Material Weakness Repeat
  • 1160131 2022-013
    Material Weakness Repeat
  • 1160132 2022-014
    Material Weakness Repeat
  • 1160133 2022-015
    Material Weakness Repeat
  • 1160134 2022-016
    Material Weakness Repeat
  • 1160135 2022-017
    Material Weakness Repeat
  • 1160137 2022-019
    Material Weakness Repeat
  • 1160138 2022-019
    Material Weakness Repeat
  • 1160139 2022-020
    Material Weakness Repeat
  • 1160140 2022-021
    Material Weakness Repeat
  • 1160141 2022-021
    Material Weakness Repeat
  • 1160142 2022-021
    Material Weakness Repeat
  • 1160143 2022-022
    Material Weakness Repeat
  • 1160144 2022-022
    Material Weakness Repeat
  • 1160145 2022-023
    Material Weakness Repeat
  • 1160146 2022-023
    Material Weakness Repeat
  • 1160147 2022-023
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $7.50M
84.425 Education Stabilization Fund $3.02M
15.875 Economic, Social, and Political Development of the Territories $1.69M
84.047 Trio Upward Bound $269,114
93.107 Area Health Education Centers $90,102
10.308 Resident Instruction, Agriculture, and Food Science Facilities and Equipment Grants $45,256
47.076 Stem Education (formerly Education and Human Resources) $16,725