Finding 1186921 (2025-001)

FINDING 2025-001 Subject: TRIO Cluster - Eligibility Federal Agency: US Department of Education Federal Program: TRIO Talent Search Assistance Listings Number: 84.044 Federal Award Number and Year (or Other Identifying Number): P044A220683 Compliance Requirement: Eligibility Audit Findings: Significant Deficiency, Other Matters This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2024-002. Condition and Context An effective internal control system was not in place at the College to ensure compliance with the Eligibility compliance requirements. The following deficiencies over determination and noncompliance were noted:  For TRIO Talent Search, 2 of the 16 students from the Northwest (Lake) Campus did not have evidence of internal controls over admission to the program.  For TRIO Talent Search, 1 of the 16 students from the Northwest (Lake) Campus of the College could not provide evidence that the participant was a citizen, national, or permanent resident of the United States or in the United States for other than a temporary purpose. The lack of internal controls was isolated to the Northwest (Lake) Campus TRIO Talent Search program. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with 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 Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 34 CFR 646.3 states: "A student is eligible to participate in a Student Support Services project if the student meets all of the following requirements: INDIANA STATE BOARD OF ACCOUNTS 18 IVY TECH COMMUNITY COLLEGE OF INDIANA SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Is a citizen or national of the United States or meets the residency requirements for Federal student financial assistance. (b) Is enrolled at the grantee institution or accepted for enrollment in the next academic term at that institution. (c) Has a need for academic support as determined by the grantee, in order to pursue successfully a postsecondary educational program. (d) Is– (1) A low-income individual; (2) A first generation college student; or (3) An individual with disabilities." Cause The College's management had not developed an effective system of internal controls that would have ensured compliance with the Eligibility compliance requirement. This was due to policies and procedures not being adequate to retain the documentation for TRIO Eligibility. Effect The failure to establish an effective internal control system could enable material noncompliance to go undetected. Noncompliance with the Eligibility compliance requirement could have resulted in the loss of federal funds to the College. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the College's management strengthen the internal controls related to the compliance requirement listed above. We also recommended strengthening its policies and procedures to ensure appropriate supporting documentation for evidence of review and other internal controls procedures for federal programs are retained to be presented for audit. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report. INDIANA STATE BOARD OF ACCOUNTS 19