Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material weakness): Information on the federal program – Educational Talent Search (ETS), FAL No. 84.044A, June 30, 2024; Upward Bound Program-Summer I & II (UB), FAL No. 84.047A, June 30, 2024; Upward Bound Program Math and Science (UB), FAL No. 84.047M, June 30, 2024; Educational Opportunity Centers ( EOC), FAL No. 84.066A, June 30, 2024 a) Upward Bound (UB) Eligibility Test Criteria – An individual is eligible to participate in a Regular, Veterans, or a Math and Science Upward Bound project if the individual meets certain criteria regarding U.S. citizenship, age, educational level, academic support needs, and classification as firstgeneration college student, low-income individual or at risk for academic failure. 34 CFR 645.3 Condition – 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. Cause – There was a high degree of staff turnover and lack of experience in the frontline staff directly responsible for internal controls over eligibility verification. Effect – The College could face reduction of funding or program termination. Questioned Costs – $41,253. Perspective – Total population of UB participants was 285. The number tested was 17. Unduplicated students with exceptions was 10. This is considered a systemic problem since eligibility noncompliances were noted across three (3) TRIO programs. Repeat Finding – No. Auditor's Recommendation – We recommend the College ensure that all required documentation is submitted prior to determining the participants' eligibility. Management’s Response – The following corrective actions will be completed by the College and the Executive Director for TRIO Programs on or before June 30, 2026. • The College will recruit and develop highly qualified personnel to ensure that controls over eligibility are implemented to include verification of citizenship, income information, tax refunds, documentation of enrollment status, enrollment agreement, and birthdates. • There will be an additional level of early review by the Executive Director and other senior program staff to verify compliance at multiple stages of program participation by students, including when students are initially recruited and enrolled. • Staff training will be performed specifically on reviewing the proper documentation required for participation in the TRIO programs. View of Responsible Officials – The College agrees with the auditor’s finding and recommendation and believes the corrective measures described above will address the issue and prevent recurrence. b) Educational Talent Search (ETS) Eligibility Test Criteria – An individual is eligible to participate in a Talent Search project if the individual meets certain criteria regarding U.S. citizenship, age, educational level, military status, and classification as first-generation college student, low-income individual or at risk for academic failure. 34 CFR 643.3 Condition – 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. Cause – There was a high degree of staff turnover and lack of experience in the frontline staff directly responsible for internal controls over eligibility verification. Effect – The College could face reduction of funding or program termination. Questioned Costs – Educational Talent Search, FAL No. 84.044A: $7,315. Perspective – Total population of ETS participants was 740. The number tested was 17. Unduplicated students with exceptions was 17. This is considered a systemic problem since eligibility noncompliances were noted across three (3) TRIO programs and noncompliance was noted for the entire sample. Repeat Finding – No. Auditor's Recommendation – We recommend the College ensure that all required documentation is submitted prior to determining the participants' eligibility. c) Educational Opportunity Centers (EOC) Eligibility Test Criteria – An individual is eligible to participate in an Educational Opportunity Centers project if the individual meets certain criteria regarding U.S. citizenship, age, military status, expressed desire for higher education and classification as first-generation college student or low-income individual. 34 CFR 644.3 Condition – 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. Cause – There was a high degree of staff turnover and lack of experience in the frontline staff directly responsible for internal controls over eligibility verification. Effect – The College could face reduction of funding or program termination. Questioned Costs – Educational Opportunity Centers, FAL No. 84.066A: $3,415. Perspective – Total population of EOC participants was 850. The number tested was 17. Unduplicated students with exceptions was 17. This is considered a systemic problem since eligibility noncompliances were noted across three (3) TRIO programs and noncompliance was noted for the entire sample. Repeat Finding – No. Auditor's Recommendation – We recommend the College ensure that all required documentation is submitted prior to determining the participants' eligibility.