Finding 502482 (2021-013)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2021
Accepted
2024-10-10
Audit: 324487
Organization: College of the Marshall Islands (MH)

AI Summary

  • Core Issue: The College failed to provide documentation showing collaboration efforts to minimize duplication of services under the TRIO Upward Bound program.
  • Impacted Requirements: Noncompliance with OMB guidelines and federal regulations regarding collaboration with other TRIO and federally funded programs.
  • Recommended Follow-Up: Enhance internal controls and compliance procedures to ensure proper documentation and collaboration efforts are in place.

Finding Text

Finding No.: 2021-013 Federal Agency: U.S. Department of Education AL Program: 84.047A TRIO Upward Bound Federal Award No.: P047A171556-21 Area: Special Tests and Provisions - Minimizing Duplication of Services under the TS and UB Programs Questioned Costs: $ Undeterminable Criteria: Per OMB Compliance Supplement July 2021, to minimize the duplication of services and promote collaborations so that more students can be served, TS and UB projects are required to collaborate with other TRIO projects, Gaining Early Awareness and Readiness for Undergraduate programs (GEAR UP) projects (Assistance Listing 84.334), or projects from other programs serving similar populations that are serving the same target schools or target area (34 CFR sections 643.11(b) and 645.21(a)(4)). In addition, the recipients of TS and UB grants are required to keep records, to the extent practicable, of any services TS or UB participants receive during the project year from another TRIO program or another federally funded program that serves populations similar to those served under the TS and UB programs (34 CFR sections 643.32(c)(5) and 645.43(c)(5)). Condition: No supporting documentation (e.g., email correspondence, advertisements, etc.) was provided to demonstrate that specified plans in the UB Grant Application Form were implemented and/or other collaboration efforts were in place during FY2021. Cause: The College lacks adequate internal control policies and procedures over compliance with applicable special tests and provisions requirements for minimizing duplication of services under the TS and UB Programs. Effect: The College is in noncompliance with applicable special tests and provisions requirements for minimizing duplication of services under the TS and UB Programs requirements. No questioned cost is presented as we are unable to quantify the extent of noncompliance. Recommendation: College management should improve internal control policies and strengthen controls over compliance with applicable special tests and provisions requirements for minimizing duplication of services under the TS and UB Programs 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

Special Tests and Provisions - Minimizing Duplication of Services under TS and UB Programs: Currently, the CMI Upward Bound program is the only TRIO program in the Republic of the Marshall Islands. Noting the need to formally document that there is no duplication, however, the college will add a question regarding whether a student is participating in any other TRIO program to its Upward Bound application form moving forward. September 30, 2022 Stevenson Kotton VPBAA Pam Kaios UB Director

Categories

Special Tests & Provisions Internal Control / Segregation of Duties

Other Findings in this Audit

  • 502480 2021-011
    Material Weakness
  • 502481 2021-012
    Material Weakness
  • 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