Finding Text
Federal Program Information:
TRIO Cluster (ALN: 84.042A and 84.047A)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
E. Eligibility – Under the Upward Bound (“UB”) program, the University may award stipends of up to $40 per month from September to May of the academic year and $60 for each of the summer months (June, July, and August) to eligible participants.
Per 34 CFR 646.30(i), Student Support Services (“SSS”) grant aid may be provided to students who have completed their first two years of postsecondary education and who are receiving Federal Pell Grants under subpart 1 of part A of title IV of the Act if the institution demonstrates to the satisfaction of the Secretary that:
• These students are at high risk of dropping out; and
• It will first meet the needs of all its eligible first- and second-year students for services under this paragraph.
Condition:
The University was unable to provide documentation supporting certain students’ eligibility to participate in the TRIO program or the amounts awarded for certain stipends.
Cause:
Insufficient administrative oversight and internal controls over TRIO program eligibility requirements.
Effect or Potential Effect:
The University was not in compliance with TRIO program eligibility requirements.
Questioned Costs:
Known questioned costs: $979; total questioned costs: indeterminable.
Context:
We noted the following exceptions during our testing:
• For 4 of 29 students selected for testing, stipend amounts under the UB program were disbursed to students in excess of the allowed monthly maximum for the academic year.
• For 1 of 6 students selected for testing, the University was not able to demonstrate that the criteria for awarding SSS TRIO grant aid to a student who had previously completed their first two years of postsecondary education was appropriately satisfied.
Identification as a Repeat Finding:
This is a repeat finding from prior year. This was reported as Finding 2023-007 in the prior year schedule of findings and questioned costs.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that documentation supporting TRIO program eligibility is appropriately retained as required.
Views of Responsible Officials:
The Student Support Services program experienced changes in program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation wasn’t available due to the transition of key program personnel. During the transition for Student Support Service, we encountered difficulty locating explicit documentation for students who were awarded Grant Aid outside of first- or second-year classification.
Section 3518(a) of the CARES Act granted the Department authority to “modify the required and allowable uses of funds” for certain programs authorized by the Higher Education Act of 1965, which included TRIO programs. The flexible extension remained in effect until September 30, 2024. Upward Bound requested a flexibility extension under the CARES Act. Due to a delayed response to the request, the extension request was re-sent for verification. Once received, UB was advised that the Department was no longer accepting new requests. As a result, stipends were processed before receiving the final response.
During the Spring of 2024 the University began work to enhance its internal controls, policies and procedures to ensure the appropriate documentation was properly maintained. While there was improvement across all TRIO programs, the issues were not fully remediated by June 30, 2024.
The University is committed to ensuring compliance with all federal, institutional, and program regulations. The University continues to enhance its internal controls, policies and procedures to ensure the appropriate documentation to support is maintained.
Both the Student Support Services and Upward Bound programs are committed to implementing continuous monitoring of program records to ensure compliance with federal, institutional, and program requirements. The TRIO-SSS program has implemented an online Grant Aid application process for all participants who are eligible for aid; which requires submission of demographic information and a need for support statement.
With the expiration of exceptions allowed under the CARES Act, all TRIO programs have converted back to distributing stipends in accordance with current federal regulations. Each program will monitor their respective distributions for accuracy and program compliance. Supporting documentation of statutory and regulatory requirements will be retained in the Policy and Procedures manuals.