Context: During the annual A-133 Audit, external auditors from Adams Brown Strategic Allies reviewed 2020-2021 Annual Performance Report documentation from Barton sponsored TRIO Programs Barton County Upward Bound, Central Kansas Upward Bound, Central Kansas Educational Opportunity Center, and Student Support Services. Findings: Student Support Services Program ? The auditors identified key reporting items from the Uniform Guidance Compliance Supplement and reviewed a sample of ten participant files relevant to the reporting items as noted in the files and on the Annual Performance Report. ? The auditors noted no discrepancies were found and concluded that "the Annual Performance Report prepared by Rita Thurber for the 2020-2021 year appear[s] to have been completed correctly in all material respects." Central Kansas Educational Opportunity Center Program ? The auditors identified key reporting items from the Uniform Guidance Compliance Supplement and reviewed a sample of ten participant files relevant to the reporting items as noted in the files and on the Annual Performance Report. ? The auditors noted no discrepancies were found and concluded that "the Annual Performance Report prepared by [Patrick Busch] (corrected: Ray Kruse) for the 2020- 2021 year appear[s] to have been completed correctly in all material respects, aside from the items noted below."* * "One student's Secondary School (or equivalent) status was reported inaccurately due to entry error." Barton County Upward Bound Program ? The auditors identified key reporting items from the Uniform Guidance Compliance Supplement and reviewed a sample of ten participant files relevant to the reporting items as noted in the files and on the Annual Performance Report. ? The auditors noted no discrepancies were found and concluded that "the Annual Performance Report prepared by Kelsey Hall for the 2020-2021 year appear[s] to have been completed correctly in all material respects, aside from the Date of First Service as noted below."** ** "When Kelsey first started, she was told to enter program acceptance date (not the enrollment), in the Date of First Project Service. However, at a new Director training recently, she learned that it should actually be the true first service date, as recorded in the activity logs." Central Kansas Upward Bound Program ? The auditors identified key reporting items from the Uniform Guidance Compliance Supplement and reviewed a sample of ten participant files relevant to the reporting items as noted in the files and on the Annual Performance Report. ? The auditors noted no discrepancies were found and concluded that "the Annual Performance Report prepared by Patrick Busch for the 2020-2021 year appear[s] to have been completed correctly in all material respects, aside from the items noted below."*** *** "Date of Last Project Service was incorrect on several students due to activities being logged after the most recent project service date was entered into the system." *** "(One participant's) eligibility status was accidentally recorded incorrectly. Likely just an entry error." Actions/Action Plan: Barton Community College assembled the appropriate TRIO and other related personnel to review the findings and identify a corrective action plan. The individuals noted below met on November 29, 2022 for this purpose. Patrick Busch, Central Kansas Upward Bound Project Director Kelsey Hall, Barton County Upward Bound Project Director Raymond Kruse, Central Kansas Educational Opportunity Center Project Director Angie Maddy, Vice President of Student Services Cathie Oshiro, Director of Grants Not present: Rita Thurber, Student Support Services Project Director ? Barton TRIO standard data entry processes were reviewed to confirm that practices are in place in each program for ensuring a double-check approach to data entry, to help minimize data entry errors. ? Kelsey Hall reported her contact with Student Access (the TRIO/Upward Bound participant tracking and reporting software that Barton County Upward Bound uses), noting to them the discrepancy between the Upward Bound APR terminology of First Date of Service as compared to Student Access' use of Program Entry Date for the same field. ? United State Department of Education (ED) guidance on reporting for TRIO programs was reviewed. It was noted that current ED guidance on Upward Bound Program Year 2021-2022 Annual Performance Reporting (0MB Approval No.: 1840-0831 0MB Control No: 1840-0831) cautions preparers against conflating Date of First Project Service and Date of Acceptance. This guidance states regarding Date of First Project Service: "Accuracy is particularly important for this field. For new students, use the date the student first received service from the Upward Bound project that is submitting this report. Do not use date of acceptance into project unless that is the same as the date of first service. Students first served in the summer program should have a date of first project service no earlier than June 1. Use the original date of service at this project even if the student subsequently left and reentered. If the student transferred from another UB project, in this field give the date of first service at the project submitting the report." However, the guidance goes on to state: "You do not need to provide the exact day; you may use 15 (midpoint of the month)." ? It was determined that, based on the review of the ED guidance, going forward the Barton County and Central Kansas Upward Bound Programs would ensure that Date of First Project Service is confirmed, double checked, and recorded as such, and not erroneously reported as Date of Acceptance, or utilize the ED-accepted "15th day of the month" designation (along with the appropriate month and year information). It was noted that the guidance allows "15th day of month" reporting for additional fields as well such as Date of First Project Service, High School Graduation, College Degree Attainment Date, Date of Certificate/Diploma, Date of Associate Degree, Date of Bachelor's Degree, and Date of Last Project Service. ? It was determined that each Upward Bound Program Director will identify an appropriate place to document the corrective action step regarding Date of First Project Service, whether within the program's policy and procedure manual or another appropriate documentation source. This step will help support accurate information and training on this item for future Upward Bound employees. The Barton team tasked with reviewing these findings and determining a plan for corrective action feel confident that the findings are understood, have been thoughtfully considered, and will be remedied based on the actions outlined here.