Finding Text
2022-003 TRIO?ELIGIBILITY (ROSWELL CAMPUS) (Significant Deficiency and Other Non-compliance) Federal Program information: Title: TRIO Cluster Funding Agency: U.S. Department of Education Pass Through: None Assistance Listings Number: 84.042, 84.044, 84.047, 84.066 Award Year: 2022 Questioned Costs: None Condition During our testing of the TRIO Student Support Services (SSS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: One student was not eligible for the program, as they did not meet the low-income threshold, nor were they a potential first generation student or individual with disabilities, nor a veteran. Eight individuals did not have proper documentation to support the verification of their low-income status. For six of these individuals, they had recorded an Expected Financial Contribution (EFC) of $0 reported in their Banner student financial aid award screen. The other two had minimal EFCs reported. The signed financial aid application itself was not used in the verification. During our testing of the TRIO Talent Search (TS) program at ENMU-Roswell for the compliance requirements under Eligibility Reporting, we noted in our sample of 40 students that: For 8 students tested, students had signed on to the program, but there was no subsequent record of any allowable activities being performed. Criteria According to the Higher Education Act of 1965, as amended; Title IV, Part A, Subpart 2, Chapter 1, Sec. 402D; 20 U.S.C. 1070a-14, applicable to all TRIO programs: (e) DOCUMENTATION OF STATUS AS A LOW-INCOME INDIVIDUAL. (1) Except in the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. (2) In the case of an independent student, as defined in section 480(d), documentation of an individual?s status pursuant to subsection (h)(4) shall be made by providing the Secretary with: (A) A signed statement from the individual?s parent or legal guardian; (B) Verification from another governmental source; (C) A signed financial aid application; or (D) A signed United States or Puerto Rico income tax return. Effect By not meeting or properly documenting the eligibility requirements, the University is not in compliance with program requirements. In the case of the ENMU-Roswell Talent Search program, by allowing students to sign on to the program, but then to not follow up with those students at a high rate, program participation was not as high as it could have been. Cause Documentation requirements for low income requirements were not uniformly well understood across all programs at each of the campuses. For low-income verification, alternative docu-mentation that did not meet the requirements was used, but where low-income status appears to have been likely. Each program at each campus is run by a separate director, which leads to non-uniform practices, file-keeping systems, and different interpretations of program requirements. The programs experienced challenges both with staff turnover, as well as unique challenges in providing services to students as a result of the COVID-19 pandemic. Recommendation We recommend that the University develop and implement uniform policies and procedures to ensure that all programs are similarly meeting eligibility requirements. The University should consider assigning an individual to monitor the uniformity of practices amongst these programs. We recommend that follow-up be performed for student who have signed on to the program, but have not participated, and that these contact attempts be documented to demonstrate due diligence.