Finding Text
Cluster Name: TRIO Cluster Assistance Listings numbers and names: 84.042 TRIO?Student Support Services 84.047 TRIO?Upward Bound Award numbers and years: P042A2000873, September 1, 2020 through August 31, 2025; P042A201342, September 1, 2020 through August 31, 2025; P042A200859 September 1, 2020 through August 31, 2025; P047A171009 September 1, 2017 through August 31, 2022; P047A1710820 September 1, 2017 through August 31, 2022 Federal agency: U.S. Department of Education Compliance requirement: Eligibility Questioned costs: $14,678 Condition?The District?s 2 TRIO offices that administer the TRIO?Upward Bound program (program) did not review and approve their eligibility determinations for 21 of 24 students? eligibility we tested for the District?s program and, contrary to federal regulation, 1 of the 2 District?s TRIO offices did not maintain records for stipends awarded to students. Specifically, we found that: ? GateWay Community College did not independently review and approve its eligibility determinations for 12 of 12 students? eligibility we tested before making awards for services, contrary to its policies and procedures. Further, South Mountain Community College did not independently review and approve its eligibility determinations for 9 of 12 students? eligibility we tested before making awards for services. We did not identify any ineligible students in the samples we tested. ? GateWay Community College did not maintain records and other documentation demonstrating how students earned stipends and how its TRIO office calculated $14,678 of the total $15,653 of stipends it awarded to students for fall and spring semesters, contrary to its policies and procedures to maintain records for stipends awarded to students. Effect?Without performing independent reviews and approvals of eligibility determinations that the colleges? policies and procedures require, Gateway and South Mountain Community Colleges have an increased risk of ineligible students participating in the program. In addition, due to Gateway Community College?s lack of stipend records, there is an increased risk that $14,678 of the stipends it awarded to students may not have been earned or correctly calculated or may have exceeded the limits permitted by the program?s requirements. Cause?GateWay Community College experienced turnover in the key personnel administering the program, and the new personnel were not aware of the college?s policies and procedures requiring review and approval of eligibility determinations. They were also unable to locate records supporting the stipends it awarded to students. Also, South Mountain Community College?s policies and procedures did not address review and approval of student records and did not incorporate this process when the College transitioned to an electronic eligibility process during the COVID-19 pandemic. Criteria?GateWay Community College?s written policies and procedures require its TRIO office to perform an independent review and approval of their student eligibility determinations before awarding students program services (GateWay Community College?TRIO Upward Bound Eligibility Determination and Intake Process). In addition, federal regulation requires each District TRIO office to maintain attendance records and other documentation demonstrating the student?s satisfactory participation in program activities to earn the stipend and records supporting the District TRIO offices? calculation of the stipends in accordance with program requirements, which limit the amount of stipends to students depending on whether the stipend is earned during the academic year or summer session (34 CFR 645.42). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The District should: 1. Require all the District?s TRIO offices that administer the TRIO?Upward Bound program to follow or update policies and procedures to: a. Require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. b. Maintain records and other documentation demonstrating how students have earned and how the District?s TRIO offices have calculated the stipends awarded to students for participating in the program?s activities. 2. Train all employees responsible for administering the TRIO programs at the District?s TRIO offices on the District-wide policies and procedures. The District?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.