Finding Text
2025-002 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Education ALN: 84.047 Criteria Per 34 CFR 643.11(b) and 645.21(a)(4) require Talent Search and Upward Bound projects to collaborate with other TRIO, GEAR UP (ALN 84.334), or similar programs serving the same target population to minimize duplication of services. Additionally, 34 CFR 643.32(c)(5) and 645.43(c)(5) require the grantees to maintain records (to the extent practicable) of services participants receive from other federally funded programs serving similar populations. Condition During our review of the special tests and provisions and eligibility for Upward Bound, we noted that MDC asks potential program participants on its intake form if they are enrolled in any other Upward Bound or Talent Search programs, presumably to ensure there is collaboration with the local programs to mitigate duplication of services. We noted that 9 program participants indicated they were enrolled in other local programs on their intake form. MDC was unable to provide evidence of collaboration with the other programs the students were enrolled in, and records in the participant file of services the participants are receiving from other TRIO programs. Questioned costs Not determinable. Cause MDC lacked sufficient internal control over compliance with collaboration and documentation requirements. MDC does not appear to conduct any follow-up with the other Upward Bound and Talent Search program(s) that the student is enrolled in, prior to enrolling them in MDC’s Upward Bound program. There does not appear to be any protocol to coordinate with other programs to avoid service overlap. Effect MDC’s lack of documentation and coordination efforts with local Upward Bound and Talent Search programs increases the risk of duplication of services for program participants. This may result in inefficient use or unreasonable costs of Federal award funds. Recommendation We recommend that MDC design and implement adequate controls over its coordination efforts with local Talent Search and Upward Bound programs to mitigate duplication of services with its program participants. There should be a tracking mechanism implemented that records services provided to participants from other Department of Education programs. Training should be provided to staff on how to adequately respond when a program participant attests to receiving services from other Department of Education programs. MDC should document its collaboration efforts with other Upward Bound and Talent Search programs to mitigate duplication of services, in each program participant’s file who attests to being enrolled in other programs.