Finding Text
Finding 2023-003 – Material Weakness: Eligibility – Compliance and Control Finding
ALN 84.042 – Student Support Services, 84.044 – Talent Search and 84.047 – Upward Bound – TRIO Cluster
Federal Agency: U.S. Department of Education
Pass-Through Entity: None
Criteria Or Specific Requirement: Uniform Guidance requires that the University ensure students participating in the program meet the eligibility requirements. Uniform Guidance also requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program.
Condition: Documentation was not remained to determine if certain participants were eligible for the program. A second review to verify accuracy of participant file documentation did not take place.
Cause: Controls over compliance are not in place as it relates to determining participant eligibility.
Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance.
Questioned Costs: Not applicable.
Context: For 2 out of 40 files selected for testing, related to Talent Search compliance documents to support the student’s eligibility were not provided. Statistical sampling was not used to test this compliance requirement.
Identification As A Repeat Finding: 2022-005, 2021-005 and 2020-006
Recommendation: We recommend that management document eligibility for each participant who receives services during the fiscal year. We also recommend that managemet put a control in place for a second review of the participant files once eligibility is determined. The second review should be properly documented with the reviewer’s signature and the date the review was performed. The second review should be performed by someone other than the preparer and who has knowledge of the grant’s eligibility requirements.
Views Of Responsible Officials: The TRIO Division at the University has established a procedure that involves the Directors and Coordinators for each program (Educational Talent Search, Upward Bound, and Student Support Services). In this process, TRIO staff compile eligibility files that contain documents used to assess student participant eligibility and the services they receive within their respective programs. Once students have completed all the required forms outlined in the checklist, Educational Advisors determine the student's eligibility for the program. After confirming eligibility and ensuring that the file is complete, it is then sent to the Executive Director of the TRIO for a second review to verify accuracy. At the end of each grant year, the Executive Director will seek the assistance of a third-party entity to conduct an external review to ensure the program's compliance.