Audit of Gaining Early Awareness and Readiness for Undergraduate Programs FINAL AUDIT REPORT ED-OIG/A07-A0033 June 2002 Our mission is to promote the efficiency, U.S. Department of Education effectiveness, and integrity of the Office of Inspector General Department’s programs and operations. Region VII - Kansas City Offic e NOTICE Statements that management practices need improvement, as well as other conclusions and recommendations in this report, represent the opinions of the Office of Inspector General. Determination of corrective action to be taken will be made by appropriate Department of Education officials. In accordance with the Freedom of Information Act (5 U.S.C. Section 552), reports issued by the Office of Inspector General are available, if requested, to members of the press and general public to the extent information contained therein is not subject to exemptions in the Act. Audit of Gaining Early Awareness and Readiness for Undergraduate Programs Table of Contents Executive Summary ......................................................................................................................1 Audit Results .................................................................................................................................3 Finding No. 1 – GEAR UP Officials Did Not Notify GPOS of Changes Regarding Warrants Issued to GEAR UP Personnel ............................................................3 Finding No. 2 – GEAR UP Officials Did Not Review Budgets Prior to Awarding Grant Funds..........................................................................................................5 Finding No. 3 – GEAR UP Program Does Not Have a Plan for Monitoring Grant Activity .......................................................................................................................6 Finding No. 4 – Eligibility Checklists Not Sufficiently Completed ..........................................7 Finding No. 5 – Sample of Technical Review Forms and Panel Summary Sheets Revealed Errors .........................................................................................................9 Background ................................................................................................................................. 12 Objectives, Scope and Methodology.......................................................................................... 15 Statement on Management Controls ......................................................................................... 16 Exhibit 1 – GEAR UP Criteria................................................................................................ 17 Appendix A – GEAR UP Officials Response to Preliminary Audit Results .......................... 19 ED-OIG/A07-A0033 Audit of Gaining Early Awareness and Readiness for Undergraduate Programs Executive Summary We found that the U.S. Department of Education’s (the Department) Gaining Early Awareness and Readiness for Undergraduate Program (GEAR UP) office did not establish and follow management controls necessary to assure that it administered the program in accordance with legislative, regulatory and internal administrative requirements. Effective management controls help safeguard assets, ensure the reliability of accounting data, promote efficient operations, and ensure compliance with established policies. Specifically, we found that the Department did not assure that: • GEAR UP officials informed Grants Policy and Oversight Service (GPOS) when changes were made with GEAR UP program staff and officials holding warrant authority, • GEAR UP program staff followed the Department’s Technical Review Plan in reviewing budget data submitted by applicants prior to awarding grant funds, • GEAR UP officials established and implemented a monitoring plan as prescribed in the Technical Review Plan, • GEAR UP program staff completed the necessary steps to determine eligibility prior to awarding grant funds, and • GEAR UP program staff adequately reviewed the completed technical review forms and panel summary sheets for completion and mathematical accuracy as required by the Technical Review Plan. We recommend that the Assistant Secretary for Postsecondary Education require that GEAR UP officials and staff follow: 1. Policies and procedures in place to inform GPOS when changes are made to warrant status of GEAR UP program staff and officials; ED-OIG A07-A0033 Page 1 2. Procedures in reviewing budgets for assurance that all expenditures and matching costs are allowable according to applicable federal regulations; 3. ED Directive, GPA 1-101 – Monitoring Discretionary Grants and Cooperative Agreements, issued March 24, 1994, and prepare a strategic monitoring plan, annual monitoring plan, and annual report as a means of providing assurance that Federal grant funds are being safeguarded; 4. Procedures in place to determine eligibility of applications prior to consideration for funding; and 5. Control procedures in place to ensure that all reviews of applications are conducted in accordance with guidelines established by GEAR UP officials. Officials of the Gaining Early Awareness and Readiness for Undergraduate Program did not provide any additional comments to the draft audit report. Appendix A to this report contains the Department’s initial response, dated April 23, 2001, to our preliminary findings. ED-OIG A07-A0033 Page 2 Audit Results We found that GEAR UP officials did not establish and follow management controls necessary to assure that they administered GEAR UP in accordance with legislative, regulatory and internal administrative requirements. GEAR UP officials did not assure that: (1) GPOS was notified when changes were made with GEAR UP program staff holding warrants, (2) program staff followed the Department’s Technical Review Plan in reviewing budget data submitted by applicants prior to awarding grant funds, (3) a monitoring plan was established and implemented as prescribed in the Technical Review Plan, (4) program staff completed the steps necessary to determine eligibility prior to awarding grant funds, and (5) program staff adequately reviewed the technical review forms and panel summary sheets for completion and mathematical accuracy as required by the Technical Review Plan. Finding No. 1 - GEAR UP Officials Did Not Notify GPOS of Changes Regarding Warrants Issued to GEAR UP Personnel Grants Policy and Oversight Service (GPOS) were not provided changes of Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) personnel in order to provide an accurate list of program officials and staff that have warrant authority to obligate GEAR UP grant funds. The list provided by GPOS did not identify the name of the official who obligated the funding for the 2000 grants. In addition, we found former GEAR UP program staff and a former GEAR UP official listed as still holding warrant authority under the GEAR UP program. The policy Procedures to Obtain A Warrant to Obligate Discretionary Grant Funds established by the Office of the Chief Financial Officer (OCFO) states that the Department authorizes the Principal Office's (PO) Senior Officer to designate certain persons to obligate grant funds. To obligate the funds that person or persons must obtain an official warrant signed and issued by the Director of the OCFO’s GPOS. In addition, it is the responsibility of the Executive Office to notify GPOS when it wants to revise or cancel a warrant when the person transfers or leaves the Department. ED-OIG A07-A0033 Page 3 GEAR UP officials did not inform GPOS when changes were made with GEAR UP program staff holding warrants. It is the responsibility of the Executive Office to notify GPOS when revisions or cancellations of warrants are necessary, including changes in programs for which warrants can be authorized and authorization amounts. GEAR UP officials were not maintaining the necessary management and quality controls to safeguard Federal discretionary grant funds. The lack of accurate warrant lists could result in the unauthorized obligation of discretionary grant funds. When we brought this matter to the attention of Department officials, they did not fully concur. The Department stated that the person who had obligated the FY 2000 funds held a warrant of the correct size for the Office of Postsecondary Education (OPE). Therefore, this official had authority to obligate the GEAR UP funds. As discussed in the body of the finding, without the necessary controls to assure an accurate listing of officials who are authorized to obligate particular discretionary grant funds, these funds could be obligated inappropriately. The obligation of FY 2000 GEAR UP grant funds was one aspect of the overall finding. In addition to this official not being identified on the list provided to us from GPOS officials, we also found that former GEAR UP staff, as well as one former Department of Education employee were still listed as having current warrant authority under the GEAR UP program. According to documentation from GPOS, it is the responsibility of the Executive Office to request revision or cancellation of a warrant when the person transfers or leaves the Department. Recommendations We recommend that the Assistant Secretary for Postsecondary Education require that: 1.1 GEAR UP officials adhere to current policies and procedures to inform GPOS when changes are made to GEAR UP staff and officials with authority to obligate discretionary grant funds (warrant status). 1.2 GEAR UP officials provide an updated list to reflect only the current GEAR UP warrants issued to GEAR UP officials, thereby deleting program staff members who are no longer assigned to GEAR UP. ED-OIG A07-A0033 Page 4 Finding No.2 – GEAR UP Officials Did Not Review Budgets Prior to Awarding Grant Funds We found that GEAR UP staff did not follow the Department’s Technical Review Plan in reviewing budget data submitted by applicants prior to awarding grant funds. Program staff informed us that proposed budgets included in the grant applications were not reviewed until after the funding slate had been approved and the awards had been made. As part of the overall grant application, for a grantee to be considered, the application must include a section detailing its proposed budget for the project. The GEAR UP application booklet (2000) indicates that 15 out of the 100 possible points available would be given for “Adequacy of Resources.” In determining the adequacy of resources, the Secretary considers the following factors: • The adequacy of support, including facilities, equipment, supplies and other resources, from the applicant organization or the lead applicant organization. • The releva nce and demonstrated commitment of each partner in the proposed project to the implementation and success of the project. • The extent to which the costs are reasonable in relation to the number of persons to be served and the anticipated results and benefits. • The potential for continued support of the project after Federal funding ends, including, as appropriate, the demonstrated commitment of appropriate entities to such support. GEAR UP program staff did not obtain a determination of whether the proposed expenditures and partner resources were allowable prior to awarding grants funds. This is contrary to Education Department General Administrative Regulations (EDGAR) § 74.25(a), which says that the budget plan for the project is approved during the award process. Each step in the Technical Review Plan needs to be completed to ensure the integrity of the award process and that all grant applications being considered meet applicable criteria. By not following its own written plan, GEAR UP management could approve a grant application that does not meet all of the elements of an eligible entity. It is the responsibility of GEAR UP management to assure that program staff follows the Technical Review Plan in its entirety before awarding grant funds. ED-OIG A07-A0033 Page 5 Recommendation We recommend that the Assistant Secretary for Postsecondary Education require: 2.1 GEAR UP officials and staff to follow its procedures in reviewing budgets for assurance that all expenditures and matching costs are allowable according to applicable federal regulations. Finding No. 3 – The GEAR UP Program Did Not Have a Plan for Monitoring Grant Activity We found that the Department had not followed the ED Directive, GPA1-101 – Monitoring Discretionary Grants and Cooperative Agreements, and its own Technical Review Plan, in the area of developing and implementing a monitoring plan. • ED Directive, GPA 1-101 – Monitoring Discretionary Grants and Cooperative Agreements provides a framework for monitoring discretionary grants and cooperative agreements in the Department of Education by establishing Department-wide standards that give general guidance to Principal Officers for preparing their monitoring plans and reports; developing monitoring methods, instruments, and procedures that are appropriate to each Principal Office; using information obtained through monitoring to improve program performance and service; meeting legislative intent; and achieving the goal of improving education. The directive indicates that all Principal Offices must develop and maintain a Strategic Monitoring Plan and an Annual Monitoring Plan. Further each Principal Offices must also submit an annual report as a means of providing assurance that Federal grant funds are being safeguarded. • The Technical Review Plan for State and Partnership Grants for FY 2000 states that a plan will be established to implement program staff monitoring and technical assistance. At the time of our review, GEAR UP management had not committed to monitoring grant funds nor had they followed their own Technical Review Plan. GEAR UP officials and program staff informed us that a monitoring policy did not exist at the time of our review. GEAR UP program staff stated that providing technical assistance to grantees, not monitoring, was their primary focus. Moreover, GEAR UP officials have told program staff that there would be no site visits to ED-OIG A07-A0033 Page 6 grantees. GEAR UP program staff also informed us that they have not been instructed on how to monitor grant activity. One of the risks of not monitoring grant funds, through site monitoring visits, is that a grantee may be using Federal funds for purposes other than intended and this abuse may go undetected. When we brought this matter to the attention of Department officials, they concurred with our finding. We were informed that all GEAR UP staff received training in conducting on-site reviews in September 2001 and each will participate in two on-site institutional reviews during fiscal year 2002. The Department’s written preliminary response, dated April 23, 2001, indicated that GEAR UP officials have contacted Program Monitoring and Information Technology (PMIT) for guidance on drafting an appropriate monitoring plan. Recommendations We recommend that the Assistant Secretary for Postsecondary Education require: 3.1 GEAR UP officials develop and implement a strategic monitoring plan, annual monitoring plan, and annual report as indicated in the ED Directive, GPA1-101 – Monitoring Discretionary Grants and Cooperative Agreements. 3.2 GEAR UP officials consider the use of grant fund monitoring as a means of providing assurance that Federal grant funds are being safeguarded. 3.3 GEAR UP management implement training plans for individual program staff members, especially in the area of monitoring grant funds. Finding No. 4 – Eligibility Checklists Not Completed We found that the checklists utilized by GEAR UP program staff to determine applicants’ eligibility were not completed. The three-page document consisted of general questions such as: • Are 50 percent of the students in the participating school(s) eligible for free or reduced lunch? • Are there at least four partners? • Is there a 50 percent match over five years in cash or in-kind? ED-OIG A07-A0033 Page 7 The majority of the questions require only a checkmark indicating “yes” or “no.” There were some questions that required a brief narrative explanation. According to the Director of the GEAR UP program, the checklist was a voluntary procedure implemented by the program office. However, the Technical Review Plan for the GEAR UP State Grants and Partnership Grants for Fiscal Year (FY) 2000 requires GEAR UP program staff to screen all accepted applications for eligibility prior to the review process. By not determining eligibility prior to selecting gr antees for funding, applicants not eligible for GEAR UP grants potentially could receive funding, and review resources are expended on applications that are not eligible for consideration. For our review, we analyzed 21 checklists, which encompassed 14 partnership and 7 state grant applications. These 21 checklists were selected from the sample generated for analysis of reviewer scores for the FY 2000 GEAR UP grant competition. Checklists were only completed on grant applications that were selected for funding; therefore, all 21 of the applicants we selected for review received funding in FY 2000. We found that: • GEAR UP program staff reviewed eligibility only after the review process for applications selected for funding had been completed. • Twenty of the 21 checklists were missing answers for at least one question. The most skipped question dealt with verification that 50 percent of students in participating schools were eligible for free or reduced lunch, a major eligibility requirement of the legislation. • Twelve of the 21 checklists did not have a narrative response with an answer or an explanation for the lack of an answer to questions that required a response. Again, the majority contained no explanation addressing the verification of the students eligible for free or reduced lunch. The Department concurred with our finding and made revisions to the Technical Review Plan for the 2001 competition to complete all eligibility checks prior to the application being read or scored. When we brought the matter regarding incomplete checklists to the Department’s attention, its response stated that the checklist is not mandatory and was designed as an internal document to merely identify all mandatory criteria and listed all essential assurances that the applications must contain. When staff knew that an applicant met the eligibility criteria or the eligibility was checked in another manner, the checklists were not completed. The response continued by stating that all applications were carefully and thoroughly reviewed to determine eligibility and no grants were awarded to applicants who were not eligible to participate. ED-OIG A07-A0033 Page 8 GEAR UP program staff did not perform the eligibility screening until after the review process had been completed. The timing of the review did not follow the guidance contained in the Technical Review Plan, which required program staff to screen all qualified applications for eligibility prior to the review process. Further, documentation should be maintained to support review of grant applications for eligibility. Recommendation We recommend that the Assistant Secretary for Postsecondary Education assure that GEAR UP program officials: 4.1 Follow the procedures in place for determining the eligibility of an applicant prior to submitting the application for review. Finding No. 5 – Sample of Technical Review Forms and Panel Summary Sheets Revealed Errors Our objective was to determine if the scores from the individual reviewer’s technical review forms were transferred correctly to the panel summary sheets and then to the funding slate. We found technical review forms and panel summary sheets completed by reviewers contained errors related to either transferring the wrong scores to summary sheets or simple mathematical errors in calculating the scores. According to the Technical Review Plan, program staff were responsible for reviewing all forms and checking for completeness and/or any major discrepancies. It further states that it is the role of program staff to review completed technical review forms for their mathematical accuracy, completion, consistency, and quality of comments in justifying scores. To address our objective, we selected a sample of partnership applications for review; in addition, we reviewed all FY 2000 state applications. Below are the results of the review. Partnership Applications From the 258 FY 2000 GEAR UP partnership grant applications received, we randomly selected 50 applications for review. The universe included both funded and non- funded applications from the FY 2000 competition. We reviewed the individual reviewer technical review forms and ED-OIG A07-A0033 Page 9 panel summary sheets for each of the selected applications. We determined that 43 of the 50 partnership applications reviewed contained some fo rm of discrepancy. Our review of the 50 partnership applications scored yielded the following results: Thirteen of the 50 applications contained some error on the technical review form or panel summary sheet related to the scores that reviewers assigned to GEAR UP grant applications. None of the errors on the 13 applications resulted in any material impact on the applicants, e.g., keeping them out of the fundable range of scores or placing them in this range when they should not have been. The largest difference on the technical review forms for the 13 applications was two points, which yielded an average score difference of more than half a point. One error resulted from scores being reversed between two criterions when the scores were transferred from the individual criteria pages to the summary page. This reversal resulted in no change to the total score. The differences noted would not have moved any of the applications into the fundable range as their average scores were well below the funding cut-off. In other instances, individual reviewers brought forward incorrect scores, failed to bring forward changed scores, did not initial changes made, or reviewer comments were typed not written. For the FY 2000 grant competition, none of the errors found in our review adversely affected any of the applications. State Applications We reviewed all 21 state grant applications that the GEAR UP program office received for FY 2000; seven of these states received funding. The universe included both funded and non- funded applications from the FY 2000 competition. We reviewed the individual reviewer technical review forms and panel summary sheets for each of the applications. We determined that 15 of the 21 State applications reviewed contained some form of discrepancy. Two of the 15 applications contained math errors. Other discrepancies noted consisted of typed comments instead of written, incomplete checklists, checklists indicating comments were written in ink when they were typed, changes made were not initialed and in one instance scores were written in pencil. For the FY 2000 grant competition, none of the errors found in our review adversely affected any of the applicants. The differences we found in average score would not have moved any applicants into or out of the fundable range. ED-OIG A07-A0033 Page 10 Not following written procedures already in place could jeopardize the integrity of the review process by funding applications in error. Further, applications that should be funded may not rank high enough to receive an award if changes are not carried forward correctly. This could potentially affect whether an applicant receives funding. The Reviewers’ Handbook: Instructional Handbook for the 2000 GEAR UP Grant Review Process--stated that reviewers were to write their evaluations in ink. The Technical Review Plan also required reviewers to independently change their scores and edit or amend their comments in ink. The Department agreed that there were errors in the technical review forms and Panel Summary Sheets. The Department stated that in the new Technical Review Plan for the 2001 competition, changes would be instituted to minimize the possibility of errors in the review process. No scores will be logged in as complete without approval from both a Department of Education employee serving as a panel monitor and another Department of Education employee serving in the control room. To further address this concern, the Department plans to dedicate one staff member in the control room to check for mathematical errors, transposed numbers, and incorrect transfer of numbers from the technical review forms to the panel summary sheets. In addition, the guidance for readers has been changed to indicate specifically that reviewers may write in ink or type their comments. Recommendation We recommend that the Assistant Secretary for Postsecondary Education assure that: 5.1 GEAR UP management follows the procedures it has in place for the application review process. ED-OIG A07-A0033 Page 11 Background Congress authorized the Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) as part of the Higher Education Amendments of 1998 (Public Law 105-244). The GEAR UP program is designed to accelerate the academic achievement of cohorts of disadvantaged middle and secondary school students. The goal is to support institutions of higher education, local schools, community-based organizations, businesses, and States in working together to help students and their parents gain needed knowledge and strengthen academic programs and student services in the schools. GEAR UP provides two types of competitive grants, partnership and state, that supports early college preparation and awareness activities at the local and state levels. OPE’s Policy, Planning, and Innovation Office currently administers the GEAR UP program. GEAR UP grants are five years in length. Partnership grants are submitted on behalf of a locally designed partnership between one or more local education agencies acting on behalf of an elementary or secondary school, one or more degree-granting institution of higher education, and at least two community organizations or entities. These other entities could include such organizations as arts groups, businesses, religious groups, college student organizations, state agencies, family organizations, or parent groups. Partnership grants must include an early intervention component. The maximum annual Federal contribution under Partnership grants is $800 per each student served. The early intervention component involves the project providing early college awareness and preparation activities for participating students through comprehensive mentoring, counseling, outreach, and supportive services. For state grants, the governor of a state designates which state agency will apply for and administer a GEAR UP grant. State projects must include both early intervention and scholarship components. The scholarship component means a project shall establish or maintain a financial assistance program that awards scholarships to GEAR UP eligible students so that they may attend institutions of higher education. Partnership grants have the option of including a scholarship component. The Department’s 1999 Performance Reports and 2001 Plans, as submitted under the requirements of the Government Performance and Results Act (GPRA), contains the GEAR UP program objectives and indicators for measuring program success. The GEAR UP program supports this objective and has as its goal to ensure that disadvantaged middle school and ED-OIG A07-A0033 Page 12 secondary school students are prepared for, pursue, and succeed in postsecondary education. The Department’s measures address the following areas related to students participating in the GEAR UP program. The objectives are to increase: ♦ Academic performance and preparation for postsecondary education of participating students; ♦ High school graduation rates and participation in postsecondary education of participating students; and ♦ Educational expectations for participating students and student and fa mily knowledge of postsecondary education options, preparation, and financing. Section 404A of the Higher Education Act of 1965 (HEA), as added by Public Law 105-244, authorizes the Secretary to establish a program that-- (1) encourages eligible entities to provide or maintain a guarantee to eligible low- income students who obtain a secondary school diploma (or its recognized equivalent), of the financial assistance necessary to permit the students to attend an institution of higher education; and (2) supports eligible entities in providing-- (A) additional counseling, mentoring, academic support, outreach, and supportive services to elementary school, middle school, and secondary school students who are at risk of dropping out of school; and (B) information to students and their parents about the advantages of obtaining a postsecondary education and the college financing options for the students and their parents. The intent of the GEAR UP program, as expressed in the legislative history surrounding the law, is to provide low income children with the assurance that financial aid for postsecondary education would be available, as well as connecting these children with mentoring and support services to enable them to succeed. The program, based upon GEAR UP program documentation, addresses the challenge of helping more low-income students become prepared academically and financially to enter into and succeed in college. According to documentation we reviewed, measuring these areas provides a means of adequately gauging the success of the GEAR UP program. ED-OIG A07-A0033 Page 13 The first GEAR UP grant was awarded in fiscal year 1999. During this first award year, the Department awarded 164 partnership grants and 21 state grants. In 2000, 73 partnership grants and seven state grants were awarded. GEAR UP appropriations for 1999 totaled $120 million, with $200 million appropriated in 2000. ED-OIG A07-A0033 Page 14 Objectives, Scope, and Methodology The purpose of our audit was to determine if the Department had implemented adequate management controls to administer the GEAR UP program in accordance with legislative, regulatory, and its own internal administrative requirements. We focused on the FY 2000 grant competition from the development of the application Technical Review Plan to the awarding of grant funds. In addition, we determined whether the measures established for the GEAR UP program as contained in the Department’s annual performance plan, under the Government Performance and Results Act (GPRA), adequately addressed the program goals as defined by the enacting legislation. To accomplish our audit objectives, we reviewed applicable laws and Federal regulations governing the enactment of the GEAR UP program. In addition, we conducted interviews with program officials and staff in the GEAR UP office located in Washington, D.C. and obtained and analyzed documentation related to the project. We reviewed all 21 funded and non- funded state applications and randomly selected 50 of the 258 funded and non- funded partnership applications that the GEAR UP office received for consideration during the FY 2000 grant competition. We conducted our fieldwork at the GEAR UP program office during the periods November 6-9 and November 28-30, 2000. We conducted an exit conference at the GEAR UP office on April 9, 2001. We continued to collect and analyze information and the GEAR UP written response to our preliminary findings, dated April 23, 2001, in our office through July 2001. We discussed our findings with GEAR UP officials again on March 11, 2002. Our audit was conducted in accordance with government auditing standards appropriate to the scope of the review described above. ED-OIG A07-A0033 Page 15 Statement on Management Controls As part of our audit, we assessed the Department’s management controls applicable to the scope of this review. This assessment included a determination of whether the processes used by the Department’s GEAR UP office related to the area of compliance with Federal regulations; and internal policies and procedures provided a reasonable level of assurance that the GEAR UP program is being appropriately administered. For the purpose of this report, we assessed and classified the significant management controls into the following categories: • Development and implementation of the Technical Review Plan • Reviewers’ scores • Funding slate Because of inherent limitations and the limited nature of our review, a study and evaluation made for the limited purposes described above would not necessarily disclose all material weaknesses in the control structure. However, our assessment disclosed weaknesses at the Department’s GEAR UP office related to the area of compliance with Federal regulations, as well as with internal policies and procedures. These weaknesses are discussed in the Audit Results section of this report. ED-OIG A07-A0033 Page 16 Exhibit 1 GEAR UP Criteria Definition of Eligible Entity: Section 404A(c) of the HEA defines an eligible grant recipient for the GEAR UP Program as — (1) a State; or (2) a partnership consisting of-- (A) one or more local educational agencies acting on behalf of - - (i) one or more elementary schools or secondary schools; and (ii) the secondary schools that students from the schools described in clause (i) would normally attend; (B) one or more degree granting institutions of higher education; and (C) at least two community organizations or entities, such as businesses, professional associations, community-based organizations, philanthropic organizations, State agencies, institutions or agencies sponsoring programs authorized under subpart 4, or other pub lic or private agencies or organizations. Program Regulations: GEAR UP program regulations (34 C.F.R. §§ 694.2 and 694.3) specify that if a partnership or State applicant has chosen the cohort method for providing early intervention services, the applicant must provide service to at least one entire grade level (cohort) of students beginning not later than the 7th grade. The cohort to be served must be from a participating school that has a 7th grade and at least 50 percent of the students must be eligible for free or reduced-price lunch under the National School Lunch Act. An exception in §694.3 (a) states that a cohort may consist of all the students in a particular grade level at one or more participating schools who reside in public housing as defined in section 3(b) (1) of the United States Housing Act of 1937. GEAR UP program regulations (34 C.F.R. § 694.7) further define the matching requirements for a partnership. For a GEAR UP partnership, the applicant must state the percentage of cost of the GEAR UP project that the partnership will provide each year from non-Federal funds and comply with this percentage for each year of the project period. The non-Federal share of the cost of the GEAR UP project must be not less than 50 percent of the total cost over the project period. The regulations stipulate that a partnership with three or fewer institutions of higher education as members may provide less than 50 percent, but not less than 30 percent, of the total cost over the project period if it includes the following: ED-OIG A07-A0033 Page 17 ♦ A fiscal agent that is eligible to receive funds under Title V (Hispanic-serving institutions), or Part B of Title III (Historically Black Colleges), or section 316 or 317 of the HEA (American Indian Tribally Controlled Colleges and Alaska Natïve and Natïve Hawaiian-serving institutions), or a local educational agency; ♦ Only participating schools with a 7th grade in which at least 75 percent of the students are eligible for free or reduced-price lunch under the National School Lunch Act; and ♦ Only local educational agencies in which at least 50 percent of the students enrolled are eligible for free or reduced-price lunch under the National School Lunch Act. ED-OIG A07-A0033 Page 18 Appendix A GEAR UP Officials Response to Preliminary Audit Results ED-OIG A07-A0033 Page 19 Audit of Gaining Early Awareness and Readiness for Undergraduate Programs Report Distribution List No. of Action Official Copies Sally Stroup, Assistant Secretary 1 Office of Postsecondary Education 1990 K Street, NW Washington, DC 20006 Other ED Offices (electronically) Chief of Staff, Office of the Secretary 1 Deputy Secretary, Office of the Deputy Secretary 1 Under Secretary, Office of the Under Secretary 1 Assistant Secretary, Office of Intergovernmental and Interagency Affairs 1 Assistant Secretary, Legislation and Congressional Affairs 1 Chief Financial Officer 1 Office of General Counsel 1 Director, Budget Services 1 Director, Office of Public Affairs 1 Director, Financial Improvement & Post Audit Operations, OCFO 1 Director, Post Audit Group, Office of Chief Financial Officer 1 Audit Liaison Officer, Office of Postsecondary Education 1 Press Secretary 1 Office of Inspector General (electronically) Inspector General 1 Deputy Inspector General 1 Assistant Inspector General for Audit 1 Assistant Inspector General for Analysis and Inspections 1 Assistant Inspector General for Investigations 1 Deputy Assistant Inspector General for Audit 1 Director, State and Local Advisory and Assistance 1 Regional inspectors General for Audit 1 each Directors, Internal Audit Teams 1 each
Gaining Early Awareness and Readiness for Undergraduate Programs.
Published by the Department of Education, Office of Inspector General on 2002-06-07.
Below is a raw (and likely hideous) rendition of the original report. (PDF)