Finding Text
Finding 2025-009 - U.S. Department of Education (ED) TRIO Cluster Programs (significant deficiency): Information on the federal program – Educational Talent Search, FAL No. 84.044A Criteria – Federal regulation 34 CFR § 643.3 establishes eligibility requirements for the TRIO Talent Search program mandates that participants must be aged 11–27, have completed the 5th grade, and be enrolled in or dropped out of middle/high school or be pursuing postsecondary education. Participants must be U.S. citizens or eligible residents, and at least 66% must be both low-income and potential first-generation college students. Grant recipients must maintain verifiable documentation supporting each participant’s eligibility status before acceptance into the program. Condition – Based on the test of participants for Educational Talent Search, two (2) out of eleven (11) participant files contained birth discrepancies or unclear age documentation preventing verification that the participants met the program’s required age criteria. As a result, participant eligibility could not be substantiated for these individuals. Cause – This issue occurred due to insufficient internal controls within the participant intake and eligibility verification process. Staff did not consistently follow established procedures for collecting, reviewing, and retaining required eligibility documentation. Additionally, no secondary review or supervisory oversight existed to confirm that age and enrollment documentation were complete prior to approving participant intake. The current filing and records management system also lacks a mechanism to clearly track missing or incomplete eligibility documents, contributing to the oversight. Effect – Failure to collect and maintain proper eligibility documentation results in noncompliance with federal regulations 34 CFR § 643.3 and TRIO program requirements, increased risk of serving ineligible participants, which can compromise the program’s required demographic composition, potential questioned costs for participants whose eligibility cannot be substantiated and possible negative impact on future TRIO funding. Question Cost – $0 Perspective – The issue represents a systemic control weakness, as 18% of participant files tested failed to include adequate documentation verifying eligibility criteria. The condition appears to reflect a widespread and recurring issue rather than an isolated oversight indicating that improvements are necessary in documentation collection, verification and recordkeeping procedures. Repeat finding – No Auditor’s recommendation – We recommend that the TRIO Director ensure that all eligibility requirements are fully documented and verified prior to accepting participants into the program. This should include implementing a standardized eligibility checklist for each participant file, conducting training for staff responsible for intake and documentation; establishing a secondary review or supervisory approval process prior to finalizing participant acceptance; and enhancing the recordkeeping system to track and flag missing documents. Management’s Response – Management acknowledges the condition identified in which two participants’ applications lacked incorrect information to verify age eligibility requirements. Management notes, this condition reflects a perceived control weakness that may impact compliance with TRIO Talent Search Program requirements. During the initial application process, parent and student data is entered into a systemgenerated application. Management acknowledges that, in instances where inaccurate information is entered (e.g., date of birth), established procedures require verification against official documentation, such as the student’s transcript. Supporting documentation for Shayla Adams and Madison Wallace is provided as evidence. Upon identifying omissions or incorrect information during the review process, management verifies the applicants’ information directly with the participants’ school as part of the secondary review process. Official documentation is obtained and reviewed, and the verified date of birth is recorded as documented on the students’ official transcripts and maintained in the participant files. The applicants’ information is entered correctly in the student database (Blumen) prior to acceptance, ensuring compliance with eligibility documentation requirements under 34 CFR § 643.3. Management is committed to addressing this issue promptly and strengthening internal controls to ensure full compliance with federal regulations. Procedures governing participant intake, eligibility verification, documentation retention, and supervisory oversight will be consistently monitored. These measures include standardized processes, increased staff accountability, and ongoing monitoring to maintain program integrity. View of responsible official – The College agrees with the finding.