Finding Text
Finding 2022-006 ? Material Weakness: Special Tests and Provisions ? 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 provide certain required services under the TRIO Cluster. 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 retained to determine if required program services were provided. 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 that all required services and activities are being provided to participants. Effect: The possibility exists that noncompliance with federal requirements could go undetected without proper controls over compliance. Questioned Costs: Not applicable. Context: For 37 out of 40 files selected for testing, documentation was not retained and controls over compliance are not in place as it relates to determining that all required services and activities are being provided to participants. Statistical sampling was not used to test this compliance requirement. In addition, for all 21 files selected for Talent Search, 3 out of 13 files related to Student Support Services and 3 out of 6 files tested for Upward Bound, documentation was not retained to support that the required services were provided to participants. Identification As A Repeat Finding: 2021-007 Recommendation: We recommend that management document required services that are provided to participants. In addition, we recommend that management put a control in place for a review of the records to ensure that the required services and activities are being provided. 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 University's TRIO Division has implemented a process across all three programs in which Educational Advisors provide brochures which outline eligibility requirements as well as the services offered to student participants. Educational Advisors also track services provided to program participants through participant sign-in. At the conclusion of each grant year, the Executive Director will solicit the services of a third-party to conduct an external review to ensure the program's compliance.