Finding 502481 (2021-012)

Material Weakness
Requirement
E
Questioned Costs
$1
Year
2021
Accepted
2024-10-10
Audit: 324487
Organization: College of the Marshall Islands (MH)

AI Summary

  • Core Issue: The College failed to maintain proper documentation for student eligibility in the TRIO Upward Bound program, leading to noncompliance with federal requirements.
  • Impacted Requirements: Eligibility criteria regarding citizenship, academic need, and completion of necessary grade levels were not met for several students, resulting in questioned costs of $24,646.
  • Recommended Follow-Up: College management should enhance internal controls and procedures to ensure all eligibility documentation is collected and verified for future participants.

Finding Text

Finding No.: 2021-012 Federal Agency: U.S. Department of Education AL Program: 84.047A TRIO Upward Bound Federal Award No.: P047A171556-21 Area: Eligibility Questioned Costs: $24,646 Criteria: Per OMB Compliance Supplement July 2021, an individual is eligible to participate in a Regular UB project if the individual meets all of the following requirements: (a) is a citizen, national, or permanent resident of the United States, or is in the United States for other than a temporary purpose; (b) is a potential first-generation college student, a low-income individual, or an individual who has a high risk for academic failure; (c) has a need for academic support in order to pursue successfully a program of education beyond high school; and (d) at the time of initial selection has completed the 8th grade but has not entered the 12th grade and is at least 13 years old but not older than 19. A veteran, regardless of age, who meets all other criteria is eligible to participate. A citizen, national, or permanent resident of the United States, includes a permanent resident of Guam, the Northern Mariana Islands, the Trust Territory of the Pacific Islands (Palau), or resident of one of the Freely Associated States - the Federated States of Micronesia or the Republic of the Marshall Islands. Moreover, 34 CFR Part 645.6(b) defines “Individual who has a high risk for academic failure” as an individual who: (a) Has not achieved at the proficient level on State assessments in reading or language arts; (b) Has not achieved at the proficient level on State assessments in math; (c) Has not successfully completed pre-algebra or algebra by the beginning of the tenth grade; or (d) Has a grade point average of 2.5 or less (on a 4.0 scale) for the most recent school year for which grade point averages are available. Furthermore, to be eligible for a stipend, participants must show evidence of satisfactory participation in project activities, including regular attendance and performance in accordance with the number of sessions in which a student participated. Stipends for regular projects may not exceed $40 per month from September to May of the academic year and $60 for each of the summer months (June, July, and August). Moreover, 34 CFR Part 645.43(c) states that for each participant, a grantee must maintain a record of the basis for the grantee’s determination that the participant is eligible to participate in the project and the basis for the grantee’s determination that the participant has a need for academic support in order to pursue successfully a program of education beyond secondary school. Condition: Of 9 students tested, aggregating $24,646 of $239,524 in total participant benefits, we noted noncompliance, as follows: 1. For 4 students listed below, no documentation was on file to support whether the individual is a citizen, national, or permanent resident of the United States (including a permanent resident of Guam, the Northern Mariana Islands, the Trust Territory of the Pacific Islands (Palau), or resident of one of the Freely Associated States - the Federated States of Micronesia or the Republic of the Marshall Islands), or is in the United States for other than a temporary purpose. 2. For 6 students listed below, it does not appear that the student has a need for academic support to successfully pursue a program of education beyond high school. Specifically, we noted that the student has either a) achieved at the proficient level on State assessments in reading or language arts; b) achieved at the proficient level on State assessments in math; c) successfully completed pre-algebra or algebra by the beginning of the tenth grade; or d) has a grade point average of higher than 2.5 (on a 4.0 scale) for the most recent school year. Further, we determined that the student does not have a high risk for academic failure, which is inconsistent with the College’s determined student eligibility status (“At high risk for academic failure”) reflected in the Annual Performance Report. 3. For 1 student (Student Case Number C000421734), it does not appear that the student has a need for academic support to successfully pursue a program of education beyond high school. Specifically, based on our examination of UB Program Recommendation Form accomplished by the student’s English and Math teachers, we noted that both teachers assigned the student a “B” grade (equivalent to 3.00 - 3.40 point in a 4.0 scale). Further, transcripts of records and/or State Assessments are not on file to support the College’s determined student eligibility status (“At high risk for academic failure”) reflected in the Annual Performance Report. 4. For 1 student (Student Case Number C000374322), no documentation was on file to support whether the individual has a need for academic support, to successfully pursue a program of education beyond high school. Further, transcripts of records and/or State Assessments are not on file to support the College’s determined student eligibility status (“At high risk for academic failure”) reflected in the Annual Performance Report. 5. For 3 students listed below, no documentation was on file to support whether the individual at the time of initial selection has completed the 8th grade but has not entered the 12th grade and is at least 13 years old but not older than 19. Cause: The College lacks adequate internal control policies and procedures over eligibility determinations, including obtaining required documentation and verification to support the College’s determination that the participant is eligible to participate in the project. Effect: The College is in noncompliance with applicable eligibility requirements. Accordingly, questioned costs of $24,646 result because the projected questioned costs exceed the $25,000 threshold. Recommendation: College management should improve internal control policies and strengthen controls so that eligibility determinations, including obtaining required documentation and verification, are performed in accordance with applicable eligibility requirements. Views of Auditee and Corrective Action Plan: The College agrees with the finding and provides details in its Corrective Action Plan.

Corrective Action Plan

Eligibility: The college noted the finding, and the program is working to gather all required documents from current and previous Upward Bound students. The program will use the college’s electronic filing system and the standards described in the Upward Bound grant application moving forward. September 30, 2022 Stevenson Kotton VPBAA Pam Kaios UB Director

Categories

Questioned Costs Eligibility Internal Control / Segregation of Duties

Other Findings in this Audit

  • 502480 2021-011
    Material Weakness
  • 502482 2021-013
    Significant Deficiency
  • 502483 2021-014
    Material Weakness Repeat
  • 502484 2021-015
    Material Weakness
  • 502485 2021-017
    Significant Deficiency Repeat
  • 502486 2021-014
    Material Weakness Repeat
  • 502487 2021-015
    Material Weakness
  • 502488 2021-016
    Material Weakness
  • 502489 2021-017
    Significant Deficiency Repeat
  • 502490 2021-014
    Material Weakness Repeat
  • 502491 2021-015
    Material Weakness
  • 502492 2021-016
    Material Weakness
  • 502493 2021-017
    Significant Deficiency Repeat
  • 502494 2021-006
    Significant Deficiency
  • 502495 2021-007
    Material Weakness
  • 502496 2021-008
    Significant Deficiency
  • 502497 2021-009
    Material Weakness
  • 502498 2021-010
    Material Weakness
  • 1078922 2021-011
    Material Weakness
  • 1078923 2021-012
    Material Weakness
  • 1078924 2021-013
    Significant Deficiency
  • 1078925 2021-014
    Material Weakness Repeat
  • 1078926 2021-015
    Material Weakness
  • 1078927 2021-017
    Significant Deficiency Repeat
  • 1078928 2021-014
    Material Weakness Repeat
  • 1078929 2021-015
    Material Weakness
  • 1078930 2021-016
    Material Weakness
  • 1078931 2021-017
    Significant Deficiency Repeat
  • 1078932 2021-014
    Material Weakness Repeat
  • 1078933 2021-015
    Material Weakness
  • 1078934 2021-016
    Material Weakness
  • 1078935 2021-017
    Significant Deficiency Repeat
  • 1078936 2021-006
    Significant Deficiency
  • 1078937 2021-007
    Material Weakness
  • 1078938 2021-008
    Significant Deficiency
  • 1078939 2021-009
    Material Weakness
  • 1078940 2021-010
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $7.01M
15.875 Economic, Social, and Political Development of the Territories $1.80M
84.047 Trio_upward Bound $314,011
84.425 Education Stabilization Fund $117,439
93.107 Area Health Education Centers Point of Service Maintenance and Enhancement Awards $94,927
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $54,944
47.076 Education and Human Resources $28,894
10.678 Forest Stewardship Program $2,422