Finding 540567 (2024-002)

Material Weakness
Requirement
AELN
Questioned Costs
-
Year
2024
Accepted
2025-03-29
Audit: 350319
Organization: Tougaloo College (MS)

AI Summary

  • Core Issue: Noncompliance with federal regulations for TRIO programs, affecting eligibility verification for students.
  • Impacted Requirements: Missing documentation for citizenship, income verification, and enrollment status for multiple students across various programs.
  • Recommended Follow-Up: Ensure all required documentation is collected and verified before determining student eligibility to avoid potential sanctions.

Finding Text

Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material weakness): Information on the federal program – Educational Talent Search, FAL No. 84.044A, June 30, 2024; Upward Bound Program-Summer, FAL No. 84.047A, June 30, 2024; Upward Bound Program Math and Science, FAL No. 84.047M, June 30, 2024; Educational Opportunity Centers, FAL No. 84.066A, June 30, 2024 Criteria – Federal regulations governing TRIO programs. Condition – Instances of noncompliance were noted as more fully described in the context below. Questioned Costs – See below Context – We observed the following conditions in connection with our testing of the TRIO programs: (a) UB Eligibility Test: of the 17 students selected for testing, one (1) student’s citizenship could not be determined, two (2) students did not provide any income information on the application, ten (10) students did not provide tax returns to verify low income as reported. (b) ETS Eligibility Test: of the 17 students selected for testing, seven (7) students' citizenship status could not be determined, documentation to support enrollment status was not provided for 17 students, one (1) student did not have any information uploaded, and one (1) student has a birthdate discrepancy. (c) Educational Opportunity Center (EOC) Eligibility Test: of the 17 participants selected for EOC testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents uploaded to adequately test the attributes, and one (1) student did not have a signature page for the EOC application. Cause – Oversight by responsible employees of properly monitoring regulatory requirements. Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions as applicable. Repeat Finding – None Auditor's Recommendation – We recommend the College ensure that all required documentation is submitted prior to determining the participants' eligibility.

Corrective Action Plan

II. Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material weakness): We observed the following conditions in connection with our testing of the TRIO programs: (a) UB Eligibility Test: Of the 17 students selected for testing, one (1) student’s citizenship could not be determined, two (2) students did not provide any income information on the application, ten (10) students did not provide tax returns to verify low income as reported. (b) ETS Eligibility Test: Of the 17 students selected for testing, seven (7) students' citizenship status could not be determined, documentation to support enrollment status was not provided for 17 students, one (1) student did not have any information uploaded, and one (1) student has a birthdate discrepancy. (c) Educational Opportunity Center (EOC) Eligibility Test: Of the 17 participants selected for EOC testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents uploaded to adequately test the attributes, and one (1) student did not have a signature page for the EOC application. Auditor's Recommendation – We recommend the College ensure that all required documentation is submitted prior to determining the participants' eligibility. Corrective Action – Tougaloo College Administration understands the importance of federal compliance. The Vice President for Strategic Initiatives & Social Justice has direct management oversight of the TRIO programs. The lack of internal controls related to UB Eligibility Test, ETS Eligibility Test, and EOC Eligibility Test (verification of citizenship, income information, tax refunds, documentation of enrollment status, enrollment agreement, and birthdate verification), a non-recurring finding, were largely caused by a high degree of staff turnover and lack of experience in the front-line staff directly responsible for these controls. Although it has proven difficult to hire and retain highly qualified staff due to higher salaries paid by other institutions for similar positions in our market, the Executive Director of the TRIO programs and leadership team has implemented the following actions to correct the findings: 1. Continue to recruit and develop internal protocols to more fully retain highly qualified personnel. 2. Continue to train staff and increase staff training specific to reviewing the proper documentation required for attending the programs. 3. Include an additional level of early review by the Executive Director and other senior program staff to verify compliance at multiple stages of program involvement by students, including when students are initially recruited and enrolled. 4. Internal federal compliance testing will be a required criteria for the staff annual evaluations reviewed by the Executive Director of TRIO programs and the Vice President for Strategic Initiatives & Social Justice.

Categories

Student Financial Aid Subrecipient Monitoring Eligibility Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 540563 2024-001
    Material Weakness
  • 540564 2024-001
    Material Weakness
  • 540565 2024-001
    Material Weakness
  • 540566 2024-001
    Material Weakness
  • 540568 2024-002
    Material Weakness
  • 540569 2024-002
    Material Weakness
  • 540570 2024-002
    Material Weakness
  • 540571 2024-002
    Material Weakness
  • 1117005 2024-001
    Material Weakness
  • 1117006 2024-001
    Material Weakness
  • 1117007 2024-001
    Material Weakness
  • 1117008 2024-001
    Material Weakness
  • 1117009 2024-002
    Material Weakness
  • 1117010 2024-002
    Material Weakness
  • 1117011 2024-002
    Material Weakness
  • 1117012 2024-002
    Material Weakness
  • 1117013 2024-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $3.83M
84.063 Federal Pell Grant Program $3.06M
93.926 Healthy Start Initiative $1.37M
93.837 Cardiovascular Diseases Research $1.22M
84.031 Higher Education_institutional Aid $763,083
84.044 Trio_talent Search $357,267
84.116 Fund for the Improvement of Postsecondary Education $335,458
15.932 Preservation of Historic Structures on the Campuses of Historically Black Colleges and Universities (hbcus). $327,711
84.033 Federal Work-Study Program $293,744
43.001 Science $270,000
84.184 Safe and Drug-Free Schools and Communities_national Programs $268,019
84.287 Twenty-First Century Community Learning Centers $255,727
10.464 Socially Disadvantaged Farmers and Ranchers Policy Research Center $210,510
97.061 Centers for Homeland Security $201,865
84.047 Trio_upward Bound $201,359
81.049 Office of Science Financial Assistance Program $200,742
84.007 Federal Supplemental Educational Opportunity Grants $198,146
84.066 Trio_educational Opportunity Centers $191,389
93.110 Maternal and Child Health Federal Consolidated Programs $167,217
93.307 Minority Health and Health Disparities Research $122,886
12.905 Cybersecurity Core Curriculum $112,600
47.076 Stem Education (formerly Education and Human Resources) $108,810
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $97,952
93.838 Lung Diseases Research $97,469
47.049 Mathematical and Physical Sciences $96,369
93.859 Biomedical Research and Research Training $96,069
47.067 Materials Development, Research, and Informal Science Education $69,907
93.389 National Center for Research Resources $48,769
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $22,632
84.425 Education Stabilization Fund $17,185
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $15,458
10.331 Gus Schumacher Nutrition Incentive Program $8,876
43.008 Office of Stem Engagement (ostem) $7,590