Finding Text
FINDING 2024-003
Subject: TRIO Cluster - Reporting
Federal Agency: US Department of Education
Federal Programs: Student Support Services, Upward Bound
Assistance Listings Numbers: 84.042A, 84.047
Federal Award Numbers and Years (or Other Identifying Numbers): P042A200749, P042A200690,
P042A201220, P042A201222,
P044A220683, P047A221086,
P047A221077
Compliance Requirement: Reporting
Audit Findings: Material Weakness, Other Matters
INDIANA STATE BOARD OF ACCOUNTS
20
IVY TECH COMMUNITY COLLEGE OF INDIANA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Condition and Context
An effective internal control system was not in place at the College to ensure compliance with
requirements related to the Reporting compliance requirement. The following errors in the reporting of key
line items (per Part 4 of the Compliance Supplement) on the fiscal year 2023 Annual Performance Report
(APR) were noted:
For Student Support Services at the Indianapolis campus, key line items were tested for
16 students. For 2 students, field 27 "College Grade Level (at the end of academic year)"
was inaccurately reported.
For Student Support Services at the Richmond campus, key line items were tested for 17
students.
o For 1 student, field 18 "Date of First Project Service" was inaccurately reported.
o For 2 students, field 19 "College Grade Level (entry into project)" was inaccurately
reported.
o For 3 students, field 23 "Enrollment Status (at the end of academic year)" was inaccurately
reported.
o For 2 students, field 24 "Academic Standing" was inaccurately reported.
o For 1 student, field 27 "College Grade Level (at end of academic year)" was inaccurately
reported.
For Upward Bound at the Indianapolis campus, key line items were tested for 6 students.
For 4 students, field 28 "Participation Level for reporting year" was inaccurately reported.
For Upward Bound at the Muncie campus, key line items were tested for 6 students.
o For 2 students, field 16 "Eligibility" was inaccurately reported.
o For 1 student, field 17 "At Risk: Reading Language Arts or Math Proficiency Not
Achieved (at time of initial selection)" was inaccurately reported.
The lack of effective internal controls and noncompliance was a systemic issue at 4 of the 7
campuses that were reported on the TRIO Program during the audit period.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
INDIANA STATE BOARD OF ACCOUNTS
21
IVY TECH COMMUNITY COLLEGE OF INDIANA
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
2 CFR 200.329(c)(1) states in part: "The recipient or subrecipient must submit performance reports
as required by the Federal award. . . ."
34 CFR 646.32(c) states in part:
"Recordkeeping. A grantee must maintain participant records that show–
(1) The basis for the grantee's determination that each participant is eligible to participate
in the project under sec. 646.3;
(2) The grantee's basis for determining the academic need for each participant;
(3) The services that are provided to each participant;
(4) The performance and progress of each participant by cohort for the duration of the
participant's attendance at the grantee's institution . . ."
Cause
The College's management had not developed an effective system of internal controls that would
have ensured compliance with the Reporting compliance requirement. The College had not developed
policies and procedures to verify that TRIO Cluster reporting agreed with supporting records.
Effect
Without the proper implementation of an effectively designed system of internal control, the College
cannot ensure reporting for TRIO Cluster is accurate and in agreement with supporting records.
Noncompliance with the reporting requirement could have resulted in the loss of federal funds to the
College.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that the College's management strengthen the internal controls related to the
compliance requirement listed above. We also recommended strengthening its policies and procedures to
ensure reporting for the TRIO Cluster programs agree with supporting records of the College.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.