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: P047A171009, September 1, 2017 through August 31, 2022;
P047A170820, September 1, 2017 through August 31, 2023; P042A200873, P042A201342, and P042A200859, September 1, 2020 through August 31, 2025;
P047A221154 and P047A221160, September 1, 2022 through August 31, 2027
Federal agency: U.S. Department of Education
Compliance requirement: Eligibility
Questioned costs: $5,612
Condition—We identified 2 issues related to eligibility. First, for 2 of the 3 District colleges that administer the TRIO Cluster, the colleges did not review and approve eligibility determinations for 20 of 60 students we tested.1 Specifically, we found that:
• For 10 of 28 students tested, GateWay Community College did not independently review and approve its eligibility determinations before awarding students services, contrary to its policies and procedures.
• For 10 of 10 students tested, South Mountain Community College did not independently review and approve its eligibility determinations before awarding students services and lacked procedures to do so.
Second, contrary to federal regulation, 1 of the 3 District’s colleges that administers the Student Support Services program awarded 6 of 20 students grant aid when the students did not meet eligibility requirements. Specifically, we found that:
• For 6 of 20 students it awarded grant aid, GateWay Community College informed us that it incorrectly awarded grant aid totaling $5,612 to these ineligible students because the students did not receive a federal Pell Grant, which is an eligibility criterion to receive grant aid for the Student Support Services program.
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, GateWay Community College could potentially be required to repay to the federal agency the $5,612 of awards it made to ineligible students.2
Cause—GateWay and South Mountain Community Colleges both experienced turnover in key personnel administering the TRIO Cluster. The new personnel at GateWay Community College were not aware of its policies and procedures requiring review and approval of eligibility determinations and grant aid requirements. South Mountain Community College’s policies and procedures did not address review and approval of student records in determining eligibility.
Criteria—GateWay Community College’s written policies and procedures require employees 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). 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 colleges that administer the TRIO Cluster to follow or update policies and procedures to require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. This includes procedures to verify whether students meet all eligibility requirements, including whether they were awarded federal Pell Grants.
2. Train all employees responsible for administering the TRIO programs at the colleges on the District-wide policies and procedures.
3. Work with Gateway Community College and the U.S. Department of Education to resolve the $5,612 in questioned costs.
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.
This finding is similar to prior-year finding 2022-105 and was initially reported in fiscal year 2022.
1 For 22 of the 22 students tested for Mesa Community College, we found that the College performed the eligibility determinations in compliance with federal regulations.
2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521)