Finding Text
Federal Program Information:
TRIO Cluster (“TRIO”) (ALN: 84.042A and 84.217A)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
E. Eligibility – Under the McNair Post-Baccalaureate Achievement (“McNair”) program, the University may award stipends of up to $2,800 per year for students engaged in approved research internships.
Per 34 CFR 646.30(i), Student Support Services (“SSS”) grant aid may be provided to students who have completed their first two years of postsecondary education and who are receiving Federal Pell Grants under subpart 1 of part A of title IV of the Act if the institution demonstrates to the satisfaction of the Secretary that:
• These students are at high risk of dropping out; and
• It will first meet the needs of all its eligible first- and second-year students for services under this paragraph.
Additionally, eligible participants for the SSS Program must meet the following requirements:
• Is a citizen or national of the United States or meets the residency requirements for federal student financial assistance;
• Is enrolled at the grantee institution or accepted for enrollment in the next academic term at that institution;
• Has a need for academic support as determined by the grantee in order to pursue successfully a postsecondary educational program; and
• Is a low-income individual, a first-generation college student, or an individual with disabilities (34 CFR sections 646.3 and 646.7)
Condition:
The University was unable to provide documentation supporting certain students’ eligibility to participate in the TRIO program or the amounts awarded for certain stipends.
Cause:
Insufficient administrative oversight and internal controls over TRIO program eligibility requirements.
Effect or Potential Effect:
The University was not in compliance with TRIO program eligibility requirements.
Questioned Costs:
Below reporting threshold.
Context:
We noted the following exceptions during our testing:
• For 3 of 16 student selected for testing, the University was unable to provide documentation supporting that approval was obtained from the U.S. Department of Education to increase the stipend amount awarded under the McNair program above the allowed annual maximum during the year before disbursements were made to the students.
• For 1 of 4 students selected for testing, the University was not able to demonstrate that the criteria for awarding SSS TRIO grant aid to a student who had previously completed their first two years of postsecondary education was appropriately satisfied.
• For 2 of 25 students selected for testing, the University was unable to provide documentation supporting the students’ eligibility for the TRIO program.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that documentation supporting TRIO program eligibility is appropriately retained as required.
Views of Responsible Officials:
The University experienced significant staffing changes in the TRIO programs. The changes in staffing lead to a loss of institutional knowledge, and interrupted policy and process enforcement. In many instance the documentation wasn’t available due to the transition of key individuals. During the period of staff transition for the McNair program, original communication showing previous approval from the Program Officer was not accessible. While the Department of Education provided correspondence granting McNair projects permission to reallocate travel funding to increase stipends for participants, given the limitations on travel capabilities due to the COVID-19 pandemic, which was subsequently confirmed by the Program Officer, we encountered difficulty locating explicit documentation approving the specific stipend increase amount.
Continuous monitoring of program records will be implemented to ensure compliance with federal, Institutional and program requirements. The programs will review existing program operating procedures manuals to identify needed updates to current policies and procedures to align with federal, institutional and program requirements. The program stall will also engage in professional development opportunities to improve grant management.