Finding Text
Finding 2023‐002 – Reporting
Information on the federal program:
Federal awarding agency: United States Department of Education (ED)
Federal Program: TRIO Cluster:
TRIO Student Support Services, Assistance Listing No. 84.042 (SSS)
TRIO Upward Bound, Assistance Listing No. 84.047 (UB)
TRIO McNair Post-Baccalaureate Achievement, Assistance Listing No. 84.217 (McNair)
Award years:
2021‐2022
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR 200.303 requires that a 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 and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Student Support Services Program Annual Performance Report (OMB No. 1840-0525) – Grantees must submit an annual performance report to ED each year of the project period.
Upward Bound, and Upward Bound Math-Science Programs Annual Performance Report (OMB No. 1840-0831) – Grantees must submit an annual performance report to ED each year of the project period.
Ronald E. McNair Post-Baccalaureate Achievement Program Performance Report (OMB No. 1840-0640) – Grantees must submit an annual performance report to the department each year of the project period.
Condition: The University’s internal controls over the review of annual performance reports for the TRIO Cluster programs, SSS, UB, and McNair, are not designed with enough precision that would allow for the identification of errors in student data entered as part of the annual performance reporting process.
Questioned costs: $0
Context: EY selected and tested key line items reported in the annual performance reports for 2021-2022 for 40 students across SSS, UB, and McNair. The 2021-2022 annual performance reports were submitted in fiscal year 2022-2023. We observed that there was not a precise enough control in place to ensure that the individual student data entered for the annual performance reports was accurate. We did observe a high-level control for the review of the annual performance report by the program directors; however, this control was not designed to identify errors in the data entered for the individual students. Expenditures for the TRIO Cluster programs totaled $1,476,031 for the fiscal year ended May 31, 2023, comprised of $275,451 for SSS, $957,166 for UB, and $243,414 for McNair.
Effect: The Department of Education uses the information conveyed in the annual performance report to assess a grantee’s progress in meeting its approved goals and objectives and to evaluate a grantee’s prior experience in accordance with the program regulations. It is important that the information reported is accurate.
Cause: The University did not have effective internal controls in place to ensure accurate information was reported in the annual performance reports.
Identification as a repeat finding, if applicable: N/A
Recommendation: The University should review its internal controls over the preparation and review of annual performance reports and design an additional control to review the individual student data entered for the annual performance reports for accuracy prior to submitting the annual performance reports to the U.S. Department of Education. The University should retain evidence of the performance of the review controls.
Views of responsible officials and planned corrective actions:
Management agrees with the finding and has developed a corrective action plan.