Finding 583920 (2023-003)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-01-04
Audit: 9669
Organization: Harris-Stowe State University (MO)
Auditor: Rubinbrown LLP

AI Summary

  • Core Issue: There is a material weakness in eligibility compliance for TRIO programs, with missing documentation for participant eligibility.
  • Impacted Requirements: Uniform Guidance mandates proper controls to verify student eligibility, which were not effectively implemented.
  • Recommended Follow-Up: Management should ensure all participant eligibility is documented and establish a second review process for accuracy, involving an independent reviewer knowledgeable about eligibility requirements.

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.

Categories

Subrecipient Monitoring Eligibility Material Weakness

Other Findings in this Audit

  • 7471 2023-006
    Significant Deficiency
  • 7472 2023-006
    Significant Deficiency
  • 7473 2023-006
    Significant Deficiency
  • 7474 2023-005
    Material Weakness Repeat
  • 7475 2023-005
    Material Weakness Repeat
  • 7476 2023-003
    Material Weakness Repeat
  • 7477 2023-003
    Material Weakness Repeat
  • 7478 2023-003
    Material Weakness Repeat
  • 7479 2023-004
    Significant Deficiency Repeat
  • 7480 2023-004
    Significant Deficiency Repeat
  • 7481 2023-004
    Significant Deficiency Repeat
  • 7482 2023-006
    Significant Deficiency
  • 583913 2023-006
    Significant Deficiency
  • 583914 2023-006
    Significant Deficiency
  • 583915 2023-006
    Significant Deficiency
  • 583916 2023-005
    Material Weakness Repeat
  • 583917 2023-005
    Material Weakness Repeat
  • 583918 2023-003
    Material Weakness Repeat
  • 583919 2023-003
    Material Weakness Repeat
  • 583921 2023-004
    Significant Deficiency Repeat
  • 583922 2023-004
    Significant Deficiency Repeat
  • 583923 2023-004
    Significant Deficiency Repeat
  • 583924 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $5.26M
84.425 Education Stabilization Fund $4.42M
84.268 Federal Direct Student Loans $661,027
15.932 Preservation of Historic Structures on the Campuses of Historically Black Colleges and Universities (hbcus). $500,000
84.047 Trio_upward Bound $469,793
84.044 Trio_talent Search $466,296
84.042 Trio_student Support Services $208,991
47.076 Education and Human Resources $182,650
84.033 Federal Work-Study Program $121,694
84.007 Federal Supplemental Educational Opportunity Grants $109,800
84.116 Fund for the Improvement of Postsecondary Education $100,108
84.031 Higher Education_institutional Aid $86,096
10.558 Child and Adult Care Food Program $8,378