Finding Text
Finding 2025-001 – Required Services to Eligible Participants Type of Finding: Significant Deficiency and Compliance Federal Grant Name and ALN: TRIO Cluster: TRIO Educational Talent Search (84.044A) Federal Agency: U.S. Department of Education (Grant ID P-044A210563-23) Compliance Requirement: N. Special Tests and Provisions Repeat Finding: No Criteria: Federal regulations stipulate that Talent Search projects must deliver certain core services to eligible participants, including academic tutoring, course selection advising, college entrance exam prep, financial aid assistance, and guidance for GED or reentry programs. This requirement is codified in 34 CFR § 643.4. Additionally, applicable provisions in the OMB Compliance Supplement (2 CFR 200, Appendix XI, Part 4 – Department of Education: Special Tests and Provisions) require auditors to verify that all required services are provided to participants. Condition: During our test of controls and compliance with Special Tests and Provisions Services that Student Support Services, Talent Search, Upward Bound or McNair Projects Must Provide, we identified one participant who did not receive a required service—specifically, no academic tutoring or college entrance exam preparation was provided during the program year. Cause: Lack of internal controls over compliance—specifically, monitoring—did not allow the College to ensure all eligible participants received the required services • Case management or service delivery records were not consistently reviewed. • There was no verification step or supervisory review confirming service delivery before participant files were closed. Effect: By not delivering at least one mandated service to the participant: • The program falls into noncompliance with 34 CFR § 643.4, risking funding eligibility. • Potentially eligible students may not receive crucial educational support, which doesn’t align with the Talent Search’s objectives to improve college readiness and access. Questioned Cost: None. Context This issue was identified during a special test focusing on required services We tested a sample of 40 from a population of 1,369 students. Only one exception was found, suggesting this may not be systemic; however, even a single instance represents noncompliance with federal regulation. Recommendation: We recommend that Talent Search management: 1. Enhance monitoring controls and documentation—implement a checklist or sign-off process ensuring each required service is either recorded or formally declined in writing before participant case closure. 2. Conduct supervisory or quality assurance reviews—periodically (e.g., monthly), review a sample of participant files to confirm all mandated services have been delivered and properly documented, with corrective action taken when omissions are identified. Views of Responsible Officials: The College agrees with the recommendation and has provided a corrective action.