Finding Text
Finding 2022-005 ? 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 controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: 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 37 out of 40 files selected for testing, related to Talent Search, Student Support Services and Upward Bound, controls over compliance are not in place as it relates to determining participant eligibility. Noted a control was implemented in October 2022 after year-end. In addition, for 2 files related to Talent Search and 1 file related to Student Support Services, 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: 2021-005 and 2020-006 Recommendation: We recommend that management 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 University's TRIO Division has implemented a process which consists of the Educational Advisors for each program (Educational Talent Search, Upward Bound, and Student Support Services) creates a file which includes documents to determine student participant eligibility for their respective programs. Once the student participants complete all required forms from the checklist, the Educational Advisors then determine the student?s eligibility for the program. Once eligibility has been established, the file is escalated to the Director of the respective programs for a second review for accuracy. 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.