Finding Text
2025-001 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Education ALN: 84.047 Criteria Per 34 CFR 644.32(a)(1), grantees shall determine the eligibility of each participant in the project at the time the individual is selected to participate. Per 34 CFR 644.32(c), grantees must also maintain a record of how the grantee determined that the participant was eligible to participate in the program under 34 CFR 644.3. Condition During our testing of 40 Educational Opportunity Centers ("EOC") participants, we found that MDC enrolled 4 individuals who had incomplete program information. We noted that each individual had left portions of the enrollment form blank. MDC was unable to produce any follow-up communication with the program participant to verify eligibility before they were enrolled in the program. As a result, MDC was unable to support all participants enrolled in EOC met the program eligibility requirements. Questioned costs Not determinable. Cause MDC lacked sufficient internal control over the review process of enrollment forms to ensure participants were eligible to be enrolled in EOC. Effect MDC’s failure to properly review and verify individual’s eligibility could result in services being provided to participants who do not meet the EOC eligibility requirements. Recommendation We recommend that MDC design and implement adequate internal control over its eligibility intake and determination process. MDC should require a program manager to verify a participant’s intake form for eligibility requirements, prior to enrolling them in its programs. MDC should also develop a protocol for how employees can respond and resolve incomplete enrollment forms. Training should be provided to all staff responsible for reviewing program eligibility forms.