![](media/image1.wmf)

[]{.mark}

February 27, 2006

> Control Number
>
> ED-OIG/X07F0002

Raymond Simon

Deputy Secretary

Office of the Deputy Secretary

U.S. Department of Education

400 Maryland Ave, SW

Washington, DC 20202

David Dunn

Acting Under Secretary

Office of the Under Secretary

U.S. Department of Education

400 Maryland Ave, SW

Washington, DC 20202

Dear Deputy Secretary Simon and Acting Under Secretary Dunn:

This Final Management Information Report, titled *Overlapping Services
in the Department of Education's Office of Postsecondary Education
Programs,* is to provide information that you may find beneficial. The
objectives of our review were to determine if Office of Postsecondary
Education (OPE) grant programs 1) have duplicative program objectives
aimed at serving like target populations and areas; and 2) if grant
programs administered by other U.S. Department of Education (Department)
offices contain program objectives that overlap with OPE grant programs.
Our review focused on the FY 2003-2004 grant programs.

An electronic copy has been provided to your Audit Liaison Officer. We
received your response dated February 10, 2006, concurring with the
finding in our draft report issued on December 29, 2005. The response is
included in its entirety as Attachment C. We made minor edits to the
report to address technical corrections and clarifications you provided
separately.

BACKGROUND

The Department establishes policy for, administers, and coordinates most
Federal assistance to education. The Department's mission is to serve
America's students to ensure that all have equal access to education and
to promote excellence in our nation's schools. Some purposes as stated
in the Department's mission include:

-   Strengthen the Federal commitment to assuring access to equal
    educational opportunity for every individual.

-   Promote improvements in the quality and usefulness of education
    through Federally supported research, evaluation, and sharing of
    information.

-   Improve the coordination of Federal education programs.

-   Improve the management of Federal education activities.

-   Increase the accountability of Federal education programs to the
    President, the Congress, and the public.

OPE administers multiple programs that award thousands of discretionary
and formula grants each year. These programs are intended to address the
national need to increase access to quality postsecondary education,
strengthen the capacity of colleges and universities, and provide
teacher and student development resources. Many programs are generally
designed to:

-   Provide financial assistance to eligible students enrolled in
    postsecondary educational institutions,

-   Improve postsecondary educational facilities and programs through
    the provision of financial support to eligible institutions,

-   Recruit and prepare disadvantaged students for the successful
    completion of postsecondary educational programs, and/or

-   Promote the domestic study of foreign languages and international
    affairs and support international education research and exchange
    activities.

The Department's Office of Vocational and Adult Education (OVAE) and
Office of Elementary and Secondary Education (OESE) administer,
coordinate, and recommend policy for improving quality and excellence of
programs that are also designed to prepare students for postsecondary
education and careers through strong high school programs and career and
technical education.

REVIEW RESULTS

OPE administers at least 41[^1] discretionary and formula grants with
duplicative program objectives serving like areas and populations. There
also are 14 OVAE and 13 OESE grant programs which overlap, completely or
in part, with OPE grant programs. All programs contained some unique
characteristics; however, there were a large number with overlapping
objectives that offered similar services to the same or overlapping
populations. Some programs may not have overlapping primary objectives;
but a secondary objective overlaps an OPE program. We believe that this
overlap is counter to the Department's mission to improve coordination
and management of Federal education programs.

The Department has recommended in past budget requests a reduction in
funding for or the elimination of some programs because they duplicate
others or can be accomplished within other programs. Congress has
sometimes followed those recommendations and other times continued to
fund programs recommended for elimination or reduction. The multiple
programs, all with their own legislation, regulations, program policies,
applications, award competitions, monitoring, and reporting requirements
are burdensome for the Department to administer. We noted little
coordination between OPE, OESE, and OVAE grant programs. We suggest that
the Department improve its coordination between programs within OPE and
throughout the Department. We also suggest that grant programs be
realigned to administer like programs by the same office within the
Department, and to continue to work with Congress to consolidate or
eliminate programs that have the same program objectives.

**Programs with Overlapping Objectives Offering Similar Services to
Overlapping Populations**

Our evaluation of OPE's discretionary and formula grants identified 42
grant programs that could be grouped by related program purposes into
eight different categories:

1.  Teacher Quality and Professional Development;

2.  Student Support for Postsecondary and Adult Education;

3.  Postsecondary Student Aid;

4.  Postsecondary Institutions;

5.  Preparation of Students for Postsecondary Education;

6.  International;

7.  Curriculum; and

8.  Training.

Because some individual programs have multiple goals and objectives,
these programs may be included in more than one category. Each program
listed in one or more of the eight categories have a similar purpose
that provides, in whole or in part, similar services to like target
groups. A table of the grant programs in each category is included as
Attachment A of the report.

####### Analysis of Overlapping Programs

We have chosen to demonstrate the extent of overlapping by providing
additional detail for three of the above categories in this report:

-   Teacher Quality and Professional Development,

-   Student Support for Postsecondary and Adult Education, and

-   Preparation of Students for Postsecondary Education.

# 

# [Teacher Quality and Professional Development]{.underline}

We identified seven OPE programs that provide funding to improve and
strengthen teacher quality and professional development, along with
increasing academic achievement. We also identified two OESE programs
that either have a similar purpose or one component of the program is
similar. The nine grant programs are listed below.

+-----------------------------------+----+----+----------+-----------+
| **Table 1: Teacher Quality and    |    |    |          |           |
| Professional Development**        |    |    |          |           |
+-----------------------------------+----+----+----------+-----------+
| **Program Name^1^**               | ** | *  | **2004   | *         |
|                                   | Of | *P | F        | *Awards** |
|                                   | fi | O^ | unding** |           |
|                                   | ce | 2^ |          |           |
|                                   | ** | ** |          |           |
+-----------------------------------+----+----+----------+-----------+
| Demonstration Projects to Ensure  | O  | T  | \$6      | 27        |
| Students with Disabilities        | PE | SD | ,912,971 |           |
| Receive a Quality Higher          |    |    |          |           |
| Education                         |    |    |          |           |
+-----------------------------------+----+----+----------+-----------+
| Preparing Tomorrow's Teachers to  | O  | T  | \$0      | 25        |
| Use Technology^3^                 | PE | SD |          |           |
+-----------------------------------+----+----+----------+-----------+
| Teacher Quality Enhancement       | O  | T  | \$88     | 19 States |
| Grants (States, Partnerships,     | PE | SD | ,887,451 |           |
| Recruitment)                      |    |    |          | 38        |
|                                   |    |    |          | Pa        |
|                                   |    |    |          | rtnership |
+-----------------------------------+----+----+----------+-----------+
| Fulbright-Hays Faculty Research   | O  | IE | \$1      | 26        |
| Abroad Fellowship Program         | PE |    | ,385,649 | F         |
|                                   |    |    |          | ellowship |
|                                   |    |    |          |           |
|                                   |    |    |          | 23        |
|                                   |    |    |          | ins       |
|                                   |    |    |          | titutions |
+-----------------------------------+----+----+----------+-----------+
| Fulbright-Hays Seminars           | O  | IE | \$2      | 10        |
| Abroad-Bilateral Projects         | PE |    | ,200,000 |           |
+-----------------------------------+----+----+----------+-----------+
| Alaska Native and Native Hawaiian | O  | ID | \$10     | 16        |
| Serving Institutions              | PE | UE | ,935,100 |           |
+-----------------------------------+----+----+----------+-----------+
| Strengthening Institutions        | O  | ID | \$80     | 53        |
|                                   | PE | UE | ,986,345 | Stre      |
|                                   |    |    |          | ngthening |
|                                   |    |    |          | 26        |
|                                   |    |    |          | Planning  |
|                                   |    |    |          |           |
|                                   |    |    |          | 207       |
|                                   |    |    |          | Con       |
|                                   |    |    |          | tinuation |
+-----------------------------------+----+----+----------+-----------+
| Improving Teacher Quality State   | OE | AI | \$2,930  | 104 SEA   |
| Grants                            | SE | TQ | ,126,132 |           |
|                                   |    |    |          | 104 SAHE  |
+-----------------------------------+----+----+----------+-----------+
| Enhancing Education through       | OE | S  | \$691    | 52        |
| Technology Program                | SE | ST | ,840,913 |           |
+-----------------------------------+----+----+----------+-----------+
|                                   | ** |    | \$       | 730       |
|                                   | To |    | 3,813    |           |
|                                   | ta |    | ,274,561 |           |
|                                   | ls |    |          |           |
|                                   | ** |    |          |           |
+-----------------------------------+----+----+----------+-----------+
| 1.  Data was obtained from the    |    |    |          |           |
|     Department's ed.gov website;  |    |    |          |           |
|     the Guide to U.S. Department  |    |    |          |           |
|     of Education Programs dated   |    |    |          |           |
|     2004; or program officials in |    |    |          |           |
|     OPE, OESE, and OVAE.          |    |    |          |           |
|                                   |    |    |          |           |
| 2.  Program Offices: Teacher and  |    |    |          |           |
|     Student Development Programs  |    |    |          |           |
|     (TSD), International          |    |    |          |           |
|     Education Programs (IE),      |    |    |          |           |
|     Institutional Development and |    |    |          |           |
|     Undergraduate Education       |    |    |          |           |
|     Programs (IDUE), Academic     |    |    |          |           |
|     Improvement and Teacher       |    |    |          |           |
|     Quality Programs (AITQ),      |    |    |          |           |
|     School Support and Technology |    |    |          |           |
|     Programs (SST).               |    |    |          |           |
|                                   |    |    |          |           |
| 3.  Project was forward funded in |    |    |          |           |
|     FY 2003 for 3 years for       |    |    |          |           |
|     \$62,094,000.                 |    |    |          |           |
+-----------------------------------+----+----+----------+-----------+

-   The seven OPE programs support increasing academic achievement by
    improving teacher quality with emphasis on technology, teaching
    students with disabilities, improving international studies, and
    strengthening curriculum development. These programs offer similar
    services such as: teacher recruitment, professional development
    activities, improving technology skills, and improving and
    strengthening academic programs of teacher education.

-   The purpose of the two OESE programs is to improve academic
    achievement by increasing the number of highly qualified teachers
    and principals by recruitment or retention and through the use of
    technology.

The OPE programs are small in comparison to the two OESE programs in the
amount of funding available. The OESE programs also are broader in scope
while the OPE programs are relatively narrower in scope.

####### [Student Support for Postsecondary and Adult Education]{.underline}

We identified nine OPE programs, that include in the various program
purposes, providing support services to postsecondary and adult students
to encourage the successful completion of their postsecondary and adult
education. Programs identified offer very similar services to low-income
students or students from disadvantaged backgrounds. Services include:
information on college admissions and financial assistance, financial
aid, and student support services, such as counseling, tutoring,
mentoring, and academic advice. For several programs, these services are
authorized along with numerous other program activities directed toward
the improvement of institutions and programs. We also identified two
OESE programs and three OVAE programs that either have a similar purpose
or one component of the program offers similar services to participants.

+---------------------------------+----+----+----------+--------------+
| ###### T                        |    |    |          |              |
| able 2: Student Support for Pos |    |    |          |              |
| tsecondary and Adult Education  |    |    |          |              |
+---------------------------------+----+----+----------+--------------+
| **Program Name^1\ ^**           | #  | #  | ####     | ######       |
|                                 | ## | ## | ## 2004  |              |
|                                 | ## | ## | Funding  | #            |
|                                 | #  | #  |          | ##### Awards |
|                                 |    |    |          |              |
|                                 | #  | ## |          |              |
|                                 | ## | ## |          |              |
|                                 | ## | ## |          |              |
|                                 | #  |  P |          |              |
|                                 | Of | O^ |          |              |
|                                 | fi | 2^ |          |              |
|                                 | ce |    |          |              |
+---------------------------------+----+----+----------+--------------+
| Student Support Services        | O  | TR | \$263    | 935          |
|                                 | PE | IO | ,030,892 |              |
+---------------------------------+----+----+----------+--------------+
| McNair Postbaccalaureate        | O  | TR | \$42     | 179          |
| Achievement                     | PE | IO | ,092,721 |              |
+---------------------------------+----+----+----------+--------------+
| Historically Black Colleges and | O  | ID | \$222    | 97           |
| Universities                    | PE | UE | ,119,992 |              |
+---------------------------------+----+----+----------+--------------+
| Historically Black Graduate     | O  | ID | \$53     | 18           |
| Institutes                      | PE | UE | ,099,851 |              |
+---------------------------------+----+----+----------+--------------+
| Educational Opportunity Centers | O  | TR | \$48     | 139          |
|                                 | PE | IO | ,971,567 |              |
+---------------------------------+----+----+----------+--------------+
| American Tribally Controlled    | O  | ID | \$23     | 35           |
| Colleges and Universities       | PE | UE | ,286,792 |              |
+---------------------------------+----+----+----------+--------------+
| Alaska Native and Native        | O  | ID | \$10     | 16           |
| Hawaiian Serving Institutions   | PE | UE | ,935,100 |              |
+---------------------------------+----+----+----------+--------------+
| Developing Hispanic Serving     | O  | ID | \$93     | 212          |
| Institutions                    | PE | UE | ,993,149 |              |
+---------------------------------+----+----+----------+--------------+
| Strengthening Institutions      | O  | ID | \$80     | 53           |
|                                 | PE | UE | ,986,345 | S            |
|                                 |    |    |          | trengthening |
|                                 |    |    |          |              |
|                                 |    |    |          | 26 Planning  |
|                                 |    |    |          |              |
|                                 |    |    |          | 207          |
|                                 |    |    |          | Continuation |
+---------------------------------+----+----+----------+--------------+
| Alaska Native Education Program | OE | AI | \$33     | 5            |
|                                 | SE | TQ | ,302,000 |              |
+---------------------------------+----+----+----------+--------------+
| Native Hawaiian Education       | OE | AI | \$32     | 10           |
| Program                         | SE | TQ | ,302,000 |              |
+---------------------------------+----+----+----------+--------------+
| Tribally Controlled             | OV |    | \$7      | 2            |
| Postsecondary Vocational and    | AE |    | ,185,355 |              |
| Technical Institutions Program  |    |    |          |              |
+---------------------------------+----+----+----------+--------------+
| Vocational Education -- Grants  | OV |    | \$14     | 31           |
| to Native Americans and Alaska  | AE |    | ,937,595 |              |
| Natives                         |    |    |          |              |
+---------------------------------+----+----+----------+--------------+
| Vocational Education -- Native  | OV |    | \$2      | 1            |
| Hawaiians                       | AE |    | ,987,519 |              |
+---------------------------------+----+----+----------+--------------+
|                                 | ** |    | *        | **1,966**    |
|                                 | To |    | *\$929,2 |              |
|                                 | ta |    | 30,878** |              |
|                                 | ls |    |          |              |
|                                 | ** |    |          |              |
+---------------------------------+----+----+----------+--------------+
| 1\. Data was obtained from the  |    |    |          |              |
| Department's ed.gov website;    |    |    |          |              |
| the Guide to U.S. Department of |    |    |          |              |
| Education Programs dated 2004;  |    |    |          |              |
| or program officials in OPE,    |    |    |          |              |
| OESE, and OVAE.                 |    |    |          |              |
|                                 |    |    |          |              |
| 2\. Program Office (PO): Trio   |    |    |          |              |
| Programs (TRIO), Institutional  |    |    |          |              |
| Development and Undergraduate   |    |    |          |              |
| Education Programs (IDUE),      |    |    |          |              |
| Academic Improvement and        |    |    |          |              |
| Teacher Quality Programs        |    |    |          |              |
| (AITQ).                         |    |    |          |              |
+---------------------------------+----+----+----------+--------------+

The 14 programs listed above have the same overall objective in
providing educational services to program participants to assist in
succeeding in postsecondary and adult education.

-   The nine OPE programs provide educational services to disadvantaged
    students to encourage continuing on to a postsecondary institution.
    Many of the programs offer financial assistance to participants and
    assist students with basic college requirements. Many of these
    programs offering support services are aimed at
    specific-populations, such as African-American, Hispanic, American
    Tribal, Alaska Native, and Native Hawaiian.

-   The two OESE programs focus on providing educational services that
    address the educational needs of Alaska Native and Native Hawaiian
    youths to further their education.

-   The three OVAE programs geared at serving three specific target
    groups, Native Americans, Alaska Natives, and Native Hawaiians,
    provide support services to students choosing to attend a
    postsecondary vocational and technical institution.

# [Preparation of Students for Postsecondary Education]{.underline}

We identified four OPE programs with the purpose of providing
educational services to elementary and secondary school students to
prepare and encourage the students to complete high school and to go on
to receive a postsecondary education. We also identified five OESE, and
one OVAE program that either have a similar purpose or component.

+-------------------------------------+------+----+------------+------+
| ######## Table 3: Preparation of St |      |    |            |      |
| udents for Postsecondary Education  |      |    |            |      |
+-------------------------------------+------+----+------------+------+
| **Program Name^1^**                 | ###  | *  | #          | ###  |
|                                     | #### | *P | ####### 20 | #### |
|                                     | # Of | O^ | 04 Funding | # Aw |
|                                     | fice | 2^ |            | ards |
|                                     |      | ** |            |      |
+-------------------------------------+------+----+------------+------+
| Gaining Early Awareness and         | OPE  | T  | \$2        | 317  |
| Readiness for Undergraduate         |      | SD | 98,230,000 |      |
| Programs (GEAR UP)                  |      |    |            |      |
+-------------------------------------+------+----+------------+------+
| Upward Bound                        | OPE  | TR | \$2        | 763  |
|                                     |      | IO | 74,097,258 |      |
+-------------------------------------+------+----+------------+------+
| Upward Bound Math & Science         | OPE  | TR | \$         | 127  |
|                                     |      | IO | 32,812,036 |      |
+-------------------------------------+------+----+------------+------+
| Talent Search                       | OPE  | TR | \$1        | 469  |
|                                     |      | IO | 44,230,198 |      |
+-------------------------------------+------+----+------------+------+
| Migrant Education -- High School    | OESE | O  | \          | 18   |
| Equivalency Program                 |      | ME | $7,884,808 |      |
+-------------------------------------+------+----+------------+------+
| Prevention and Intervention         | OESE | SA | \$         | 52   |
| Programs for Children and Youths    |      | SA | 48,395,000 |      |
| Who Are Neglected, Delinquent, or   |      |    |            |      |
| At Risk                             |      |    |            |      |
+-------------------------------------+------+----+------------+------+
| Education of Migratory Children     | OESE | O  | \$3        | 52   |
|                                     |      | ME | 93,577,113 |      |
+-------------------------------------+------+----+------------+------+
| Alaska Native Education Program     | OESE | AI | \$         | 5    |
|                                     |      | TQ | 33,302,000 |      |
+-------------------------------------+------+----+------------+------+
| Native Hawaiian Education Program   | OESE | AI | \$         | 10   |
|                                     |      | TQ | 32,302,000 |      |
+-------------------------------------+------+----+------------+------+
| Tech Prep Demonstration Program     | OVAE | S  | \          | 23   |
|                                     |      | TE | $3,628,563 |      |
+-------------------------------------+------+----+------------+------+
|                                     | **   |    | **\$1,268  | *    |
|                                     | Tota |    | ,458,976** | *1,8 |
|                                     | ls** |    |            | 36** |
+-------------------------------------+------+----+------------+------+
| 1.  Data was obtained from the      |      |    |            |      |
|     Department's ed.gov website;    |      |    |            |      |
|     the Guide to U.S. Department of |      |    |            |      |
|     Education Programs dated 2004;  |      |    |            |      |
|     or program officials in OPE,    |      |    |            |      |
|     OESE, and OVAE.                 |      |    |            |      |
|                                     |      |    |            |      |
| 2.  Program Office: Teacher and     |      |    |            |      |
|     Student Development Programs    |      |    |            |      |
|     (TSD); TRIO Programs (TRIO),    |      |    |            |      |
|     Office of Migrant Education     |      |    |            |      |
|     (OME), Academic Improvement and |      |    |            |      |
|     Teacher Quality Programs        |      |    |            |      |
|     (AITQ), Student Achievement and |      |    |            |      |
|     School Accountability Programs  |      |    |            |      |
|     (SASA), and Secondary and       |      |    |            |      |
|     Technical Education (STE).      |      |    |            |      |
+-------------------------------------+------+----+------------+------+

-   All four OPE programs provide educational services that promote
    academic preparation designed to increase the number of low-income
    students who are prepared to enter and succeed in postsecondary
    education. The programs offer very similar services including
    information on postsecondary education and funding opportunities,
    encouragement and assistance to complete high school, mentoring, and
    tutoring, and are aimed at disadvantaged youth in elementary and
    secondary schools.

-   The OESE programs all contain segments that encourage graduation (or
    receipt of a GED) and enrollment in postsecondary education for
    specific sub-populations: migrant workers' children, Alaska Natives,
    Native Hawaiians, and youth in local and state institutions for
    neglected and delinquent youth.

-   The single OVAE program provides similar services for students with
    aspirations to vocational and technical education programs.

In some cases, the individuals in the sub-populations covered under the
OESE and OVAE programs would also be considered eligible under the OPE
programs' definitions of eligible students.

**Consequences of Multiple-Programs with Overlapping Objectives and
Services\
**

The multiple programs, all with their own legislation, regulations,
program policies, applications, award competitions, monitoring, and
reporting requirements are burdensome for the Department to administer.
We noted little coordination between OPE, OESE, and OVAE grant programs.
We suggest that the Department improve its coordination between programs
within OPE and throughout the Department. We also suggest that grant
programs be realigned to administer like programs by the same office
within the Department, and to work with Congress to consolidate or
eliminate programs that have the same program objectives.

#### Multiple Programs Are Burdensome to Administer

The multiple programs provide numerous flexibilities in funding services
to various entities and individuals. However, the multiple programs,
each with their own legislation, regulations, program policy,
application, award, and reporting requirements are burdensome for the
Department to administer. Since 2002, the Office of Inspector General
(OIG) has issued three internal reports and 24 recipient reports
covering programs where we found non-compliance and poor program
administration at the Department and individual grantees.[^2] Past audit
reports have shown that there is a need for the Department to increase
its monitoring, provide more technical assistance, and clarify program
guidance to reduce confusion and misinterpretation of policy guidelines.
These findings were due in part to program staff not following
prescribed policy and procedures, and not having controls in place to
effectively administer their program. Program staff stated that their
caseload and diverting staff to assist with other program award cycles
were barriers to monitoring the grants as they desired.

This administrative burden is reflected in the Department's Report to
Employees on Agency Results, July 2005, which reported, ". . . despite
the tremendous growth in the size of ED programs over the past 25 years,
the number of full-time equivalent ED staff reached a 25-year low . . .
in fiscal year 2004. Managing significantly greater resources with fewer
people . . . .*"*

Eliminating or combining programs could help reduce the burden on
program staff and reduce the amount of different, yet overlapping
program guidance, award competitions, and other materials. Realignment
of programs may also allow the Department to leverage or better use
oversight resources. This may lead to increased efficiency and better
use of the Department's resources in direct support of its mission.

#### More Coordination Needed Within OPE and With OESE and OVAE

There was little effort to coordinate between the programs, either
within OPE itself, or with OPE and OESE or OPE and OVAE. In accordance
with one purpose of the Department's mission: "to improve the
coordination of federal education programs," coordinating OPE programs,
along with programs administered in other Principal Offices, could help
ensure efficient and effective use of taxpayer resources. All Principal
Offices should coordinate programs offering similar services to meet the
needs of all individuals seeking project services, and ensure that
duplication does not exist by serving the same target group with like
services. In some cases, effective coordination might require that
programs be administered by another office.

The Talent Search and Gear Up grants in OPE are two of the more closely
related programs within the Preparation of Students for Postsecondary
Education grouping; however, they are not even administered by the same
program office within OPE. Many Talent Search grantees also are
administrating GEAR UP grants. However, there is no assurance that the
programs are not over-serving one area while overlooking another
altogether, and efforts to coordinate the award of the grants would be
more difficult when they are administered out of two different program
offices within OPE.

In the Teacher Quality and Professional Development group of programs,
the largest grant programs by far are administered by OESE. In contrast,
the largest OPE program, the Teacher Quality Enhancement Grant program,
with a total of \$88,887,451 appropriated for FY 2004, was listed for
termination in the Department's 2006 Budget request due to its lack of
performance information and program management deficiencies.

The Department also recommended eliminating the GEAR UP, Upward Bound,
and Talent Search Programs in its FY 2006 budget request. The
Department's reasons for eliminating existing programs include
indications that programs

-   have achieved their original purpose,

-   duplicate other programs,

-   may be carried out with flexible state formula grant funds, or

-   involve activities that are better or more appropriately supported
    through state, local, or private resources.

In administering programs, the flexibility and control to allocate funds
to activities determined to best meet the needs of at-risk students
should be a primary goal. Since OPE does not award discretionary grants
by geographic location, the Department cannot be certain that all
geographic areas are being served, or what portion of eligible
populations have been over- or under-served by discretionary grant
programs. Grant awards should be managed so that services are matched to
the needs of various populations both within that program and among
other programs with similar objectives.

####### The Department Should Continue to Work With Congress to Consolidate or Eliminate Overlapping Programs 

As noted, the Department has made recommendations to eliminate some
duplicative programs by recommending that the funding be discontinued.
We also acknowledge that Congress sets the number and nature of the
programs through legislation. Although the Department must administer
all the programs enacted by Congress, we believe that OPE should
increase its efforts to identify and inform Congress of inefficiencies
and overlaps between programs and to identify those programs which,
through consolidation or elimination could improve the efficiency and
effectiveness of the Department in achieving its goals of academic
excellence and expanded access to higher education.

Suggestions

We suggest that the Department consider:

1.  Continuing its work with Congress to consolidate or eliminate
    programs that have the same or similar program objectives.

2.  Realigning similar grant programs to be administered by the same
    office within the Department.

3.  Improving coordination between OPE and other Department programs
    with the same or similar program objectives.

```{=html}
<!-- -->
```
a.  Such coordination may require the reassignment of administrative
    responsibilities between program offices within OPE or the transfer
    of programs between OPE, OESE, or OVAE.

b.  The Department should explore creative ways to ensure that similar
    services offered to like populations be coordinated between the
    existing programs so that individuals and geographic areas are
    neither over- or under-served.

c.  Other areas of coordination could include identifying overlapping
    areas wherever possible and ensuring consistent application of
    definitions, guidance, and other requirements to reduce the burden
    of Departmental policy on grant administrators and grant recipients.

d.  The Department should encourage consolidation of reporting and
    similar requirements for recipients with multiple grants to reduce
    the administrative costs and enable more services to be provided to
    the intended beneficiaries.

OBJECTIVES, SCOPE, AND METHODOLOGY

The objectives of our review were to determine if OPE grant programs 1)
have duplicative program objectives aimed at serving like target
populations and areas; and 2) if grant programs administered by other
Department offices contain program objectives that overlap with OPE
grant programs.

To achieve the review objectives, we

-   Conducted interviews with program directors and staff of selected
    programs from OPE, OESE, and OVAE.

-   Obtained and reviewed program data.

-   Identified and selected all discretionary and formula OPE grant
    programs that offer similar services to a general population or
    area. (Programs that had unique program purposes were not selected.)

-   Selected OESE programs that had a similar program objective to OPE
    programs.

-   Selected OVAE programs that had a similar program objective to OPE
    programs.

-   Reviewed legislation and regulations governing each of the selected
    OPE programs.

-   Reviewed prior issued OIG audit reports pertaining to selected
    programs from each of the three Principal Offices.

-   Reviewed grant application instructions, the 2004 Program Assessment
    Rating Tool, the Department's FY 2005 Performance Plan, and the
    Department's Strategic Plan 2002-2007.

We assigned the programs selected to eight different categories of
related program purposes: Teacher Enhancement, Postsecondary Student
Services, Postsecondary Student Aid, Postsecondary Institutions,
Elementary and Secondary, International, Curriculum, and Training
Programs (See Attachment A). Because some individual programs have
multiple goals and objectives, these programs may be included in more
than one category.

We compared all programs selected from OESE and OVAE for similarities
between services, target groups, and target areas and compared those
programs to OPE programs. We did not compare programs selected within
OESE or OVAE, nor did we compare selected programs between OESE and
OVAE. Programs selected from OESE and OVAE were only compared to OPE
programs that were selected for our review.

We relied, in part, on computer-processed data to determine the number
of grant programs in each of the three Principal Offices: OPE, OESE, and
OVAE. Based on our assessments, we concluded that the data used was
sufficiently reliable for the purpose of our review. We did not assess
the adequacy of OPE, OESE, or OVAE controls over the programs selected
for review.

Fieldwork was performed at the selected OPE, OESE, and OVAE program
offices during the periods of December 8-10, 2004, and January 10-14,
2005. We conducted an exit conference with officials from OPE on October
6, 2005. Our review focused on the FY 2003-2004 individual program
objectives. Our review was conducted in accordance with generally
accepted government auditing standards appropriate to the scope of the
review described above.

ADMINISTRATIVE MATTERS

### Statements that managerial practices need improvements, as well as other conclusions and suggestions in this report, represent the opinions of the Office of Inspector General.  {#statements-that-managerial-practices-need-improvements-as-well-as-other-conclusions-and-suggestions-in-this-report-represent-the-opinions-of-the-office-of-inspector-general. .unnumbered}

In accordance with the Freedom of Information Act (5 U.S.C. § 552),
reports issued by the Office of Inspector General are available to
members of the press and general public to the extent information
contained therein is not subject to exemptions in the Act.

We appreciate the cooperation given us during this review. If you have
any questions, please contact Richard J. Dowd, Regional Inspector
General for Audit, at (312) 886-6503.

> Sincerely,

/s/

> Helen Lew
>
> Assistant Inspector General for Audit Services

Attachments

###### [Attachment A]{.underline}

**Grant Programs Within OPE With Overlapping Purposes and Services,
Including OESE and OVAE Programs Which Overlap OPE Grant Programs**

+-----------------------------------+----------------------------------+
| ######### Teacher Qua             | **Student Support for            |
| lity and Professional Development | Postsecondary and Adult          |
|                                   | Education**                      |
+-----------------------------------+----------------------------------+
| **OPE PROGRAMS**                  | **OPE PROGRAMS**                 |
+-----------------------------------+----------------------------------+
| Demonstration Projects to Ensure  | \*Student Support Services       |
| Students with Disabilities        | \$263,030,892                    |
| Receive a Quality Higher          |                                  |
| Education \$6,912,971             |                                  |
+-----------------------------------+----------------------------------+
| Preparing Tomorrow\'s Teachers to | McNair Postbaccalaureate         |
| Use Technology (no funding in     | Achievement \$42,092,721         |
| 2004)                             |                                  |
+-----------------------------------+----------------------------------+
| Teacher Quality Enhancement       | \*Historically Black Colleges    |
| Grants (States, Partnerships,     | and Universities \$222,119,992   |
| Recruitment) \$88,887,451         |                                  |
+-----------------------------------+----------------------------------+
| \*Fulbright-Hays Faculty Research | \*Historically Black Graduate    |
| Abroad Fellowship Program         | Institutions \$53,099,851        |
| \$1,385,649                       |                                  |
+-----------------------------------+----------------------------------+
| \*Fulbright-Hays Seminars         | Educational Opportunity Centers  |
| Abroad-Bilateral Projects         | \$48,971,567                     |
| \$2,200,000                       |                                  |
+-----------------------------------+----------------------------------+
| \*Alaska Native and Native        | \*American Tribally Controlled   |
| Hawaiian Serving Institutions     | Colleges and Universities        |
| \$10,935,100                      | \$23,286,792                     |
+-----------------------------------+----------------------------------+
| \*Strengthening Institutions      | \*Alaska Native and Native       |
| \$80,986,345                      | Hawaiian Serving Institutions    |
|                                   | \$10,935,100                     |
+-----------------------------------+----------------------------------+
| **OESE PROGRAMS**                 | \*Developing Hispanic-Serving    |
|                                   | Institutions \$93,993,149        |
+-----------------------------------+----------------------------------+
| Improving Teacher Quality State   | \*Strengthening Institutions     |
| Grants \$2,930,126,132            | \$80,986,345                     |
+-----------------------------------+----------------------------------+
| \*Enhancing Education through     | **OESE PROGRAMS**                |
| Technology Program \$691,840,913  |                                  |
+-----------------------------------+----------------------------------+
|                                   | \*Alaska Native Education        |
|                                   | Program \$33,302,000             |
+-----------------------------------+----------------------------------+
|                                   | \*Native Hawaiian Education      |
|                                   | Program \$32,302,000             |
+-----------------------------------+----------------------------------+
|                                   | **OVAE PROGRAMS**                |
+-----------------------------------+----------------------------------+
|                                   | \*Tribally Controlled            |
|                                   | Postsecondary Vocational and     |
|                                   | Technical Institutions Program   |
|                                   | \$7,185,355                      |
+-----------------------------------+----------------------------------+
|                                   | Vocational Education - Native    |
|                                   | Hawaiians \$2,987,519            |
+-----------------------------------+----------------------------------+
|                                   | Vocational Education - Grants to |
|                                   | Native Americans and Alaska      |
|                                   | Natives \$14,937,595             |
+-----------------------------------+----------------------------------+

  --------------------------- ------------------------- ------------------------
  **Postsecondary Student     **Postsecondary           **Preparation of
  Aid**                       Institutions**            Students for
                                                        Postsecondary
                                                        Education**

  **OPE PROGRAMS**            **OPE PROGRAMS**          **OPE PROGRAMS**

  \*Gaining Early Awareness   \*Historically Black      \*Gaining Early
  and Readiness for           Colleges and Universities Awareness and Readiness
  Undergraduate Programs      \$222,119,992             for Undergraduate
  \$298,230,000                                         Programs \$298,230,000

  B.J. Stupak Olympic         \*Strengthening           Upward Bound
  Scholarships \$988,135      Institutions \$80,986,345 \$274,097,258

  Robert C. Byrd Honors       \*Developing              Upward Bound Math &
  Scholarship \$40,758,100    Hispanic-Serving          Science \$32,812,036
                              Institutions \$93,993,149 

  \*Student Support Services                            \*Talent Search
  \$263,030,892                                         \$144,230,198

  Thurgood Marshall Legal     \*Historically Black      **OESE PROGRAMS**
  Educational Opportunity     Graduate Institutions     
  (not funded in 2004)        \$53,099,851              

  Graduate Assistance in      \*American Tribally       Prevention and
  Areas of National Need      Controlled Colleges and   Intervention Programs
  \$30,616,292                Universities \$23,286,792 for Children and Youths
                                                        Who Are Neglected,
                                                        Delinquent, or At Risk
                                                        \$48,395,000

  Jacob K. Javits Fellowship  \*Alaska Native and       Education of Migratory
  Program \$9,876,383         Native Hawaiian Serving   Children \$393,577,113
                              Institutions \$10,935,100 

  Foreign Language and Area   \*Fund for the            Migrant Education - High
  Studies Fellowship          Improvement of            School Equivalency
  \$26,960,000                Postsecondary             Program \$7,884,808
                              Education-Comprehensive   
                              Program \$11,100,000      

  Child Care Access Means     **OVAE PROGRAMS**         \*Alaska Native
  Parents in School Program                             Education Program
  \$16,098,455                                          \$33,302,000

  \*Fulbright-Hays-Doctoral    \*Tribally Controlled    \*Native Hawaiian
  Dissertation Research       Postsecondary Vocational  Education Program
  Abroad \$4,440,379          and Technical             \$32,302,000
                              Institutions Program      
                              \$7,185,355               

  \*Alaska Native and Native                            **OVAE PROGRAMS**
  Hawaiian Serving                                      
  Institutions \$10,935,100                             

  **OESE PROGRAMS**                                     \*Tech Prep
                                                        Demonstration Program
                                                        \$3,628,563

    Migrant Education-College                           
  Assistance Migrant Program                            
  \$15,667,075                                          

  **OVAE PROGRAMS**                                     

   \*Tribally Controlled                                
  Postsecondary Vocational                              
  and Technical Institutions                            
  Program \$7,185,355                                   
  --------------------------- ------------------------- ------------------------

+------------------------+-----------------------+---------------------+
| #                      | **Curriculum**        | **Training**        |
| ######## International |                       |                     |
+------------------------+-----------------------+---------------------+
| **7OPE PROGRAMS**      | **OPE PROGRAMS**      | **OPE PROGRAMS**    |
+------------------------+-----------------------+---------------------+
| American Overseas      | Eisenhower Regional   | TRIO Dissemination  |
| Research Centers       | Mathematics and       | Partnership         |
| \$1,000,000            | Science Education     | \$4,374,000         |
|                        | Consortia             |                     |
|                        | \$14,814,078          |                     |
+------------------------+-----------------------+---------------------+
| \*Fulbright-Hays       | \*American Tribally   | Training Program    |
| Faculty Research       | Controlled Colleges   | for Federal TRIO    |
| Abroad Fellowship      | and Universities      | Programs            |
| Program \$1,385,649    | \$23,286,792          | \$6,000,000         |
+------------------------+-----------------------+---------------------+
| \*Fulbright-Hays Group | \*Business and        |                     |
| Projects Abroad        | International         |                     |
| \$4,312,450            | Education Program     |                     |
|                        | \$4,490,000           |                     |
+------------------------+-----------------------+---------------------+
| \*Fulbright-Hays       | Centers for           |                     |
| Seminars Abroad        | International         |                     |
| Bilateral Projects     | Business Education    |                     |
| \$2,200,000            | \$10,700,000          |                     |
+------------------------+-----------------------+---------------------+
| \*Fulbright-Hays       | \*Fulbright-Hays      |                     |
| Doctoral Dissertation  | Group Projects Abroad |                     |
| Research Abroad        | \$4,312,450           |                     |
| \$4,440,379            |                       |                     |
+------------------------+-----------------------+---------------------+
| \*Business and         | International         |                     |
| International          | Research and Studies  |                     |
| Education Program      | \$5,620,900           |                     |
| \$4,490,000            |                       |                     |
+------------------------+-----------------------+---------------------+
| Institute for          | \*Language Resource   |                     |
| International Public   | Centers \$4,850,000   |                     |
| Policy \$1,639,330     |                       |                     |
+------------------------+-----------------------+---------------------+
|                        | \*Technological       |                     |
|                        | Innovation &          |                     |
|                        | Cooperation for       |                     |
|                        | Foreign Information   |                     |
|                        | Access \$1,700,000    |                     |
+------------------------+-----------------------+---------------------+
|                        | Undergraduate         |                     |
|                        | International Studies |                     |
|                        | and Foreign Language  |                     |
|                        | Program \$4,490,000   |                     |
+------------------------+-----------------------+---------------------+
|                        | \*Alaska Native and   |                     |
|                        | Native Hawaiian       |                     |
|                        | Serving Institutions  |                     |
|                        | \$10,935,100          |                     |
+------------------------+-----------------------+---------------------+
|                        | \*Developing          |                     |
|                        | Hispanic-Serving      |                     |
|                        | Institutions          |                     |
|                        | \$93,993,149          |                     |
+------------------------+-----------------------+---------------------+
|                        | **OESE PROGRAMS**     |                     |
+------------------------+-----------------------+---------------------+
|                        | \*Alaska Native       |                     |
|                        | Education Program     |                     |
|                        | \$33,302,000          |                     |
+------------------------+-----------------------+---------------------+
|                        | \*Native Hawaiian     |                     |
|                        | Education Program     |                     |
|                        | \$32,302,000          |                     |
+------------------------+-----------------------+---------------------+
|                        | \*Mathematics and     |                     |
|                        | Science Partnerships  |                     |
|                        | \$149,115,000         |                     |
+------------------------+-----------------------+---------------------+
|                        | \*Enhancing Education |                     |
|                        | through Technology    |                     |
|                        | Program \$691,840,913 |                     |
+------------------------+-----------------------+---------------------+
|                        | **OVAE PROGRAMS**     |                     |
+------------------------+-----------------------+---------------------+
|                        | \*Pacific Vocational  |                     |
|                        | Education Improvement |                     |
|                        | Program \$1,510,015   |                     |
+------------------------+-----------------------+---------------------+
|                        | \*College and Career  |                     |
|                        | Transitions           |                     |
|                        | Initiative            |                     |
+------------------------+-----------------------+---------------------+
|                        | \*Vocational          |                     |
|                        | Education-Basic       |                     |
|                        | Grants to States      |                     |
|                        | \$1,168,239,440       |                     |
+------------------------+-----------------------+---------------------+
| 2004 Funding shown     |                       |                     |
|                        |                       |                     |
| \*Program included in  |                       |                     |
| more than one category |                       |                     |
+------------------------+-----------------------+---------------------+

####  

#### Attachment B

+--------+---------------+-------+------------------------+---+----------+
| #      |               |       |                        |   |          |
| Office |               |       |                        |   |          |
|  of In |               |       |                        |   |          |
| specto |               |       |                        |   |          |
| r Gene |               |       |                        |   |          |
| ral Is |               |       |                        |   |          |
| sued R |               |       |                        |   |          |
| eports |               |       |                        |   |          |
+--------+---------------+-------+------------------------+---+----------+
| *      | **Title**     | *     | **Issues Identified**  | * |          |
| *Audit |               | *Date |                        | * |          |
| C      |               | Iss   |                        | R |          |
| ontrol |               | ued** |                        | e |          |
| Nu     |               |       |                        | c |          |
| mber** |               |       |                        | o |          |
|        |               |       |                        | m |          |
|        |               |       |                        | m |          |
|        |               |       |                        | e |          |
|        |               |       |                        | n |          |
|        |               |       |                        | d |          |
|        |               |       |                        | e |          |
|        |               |       |                        | d |          |
|        |               |       |                        | R |          |
|        |               |       |                        | e |          |
|        |               |       |                        | c |          |
|        |               |       |                        | o |          |
|        |               |       |                        | v |          |
|        |               |       |                        | e |          |
|        |               |       |                        | r |          |
|        |               |       |                        | y |          |
|        |               |       |                        | A |          |
|        |               |       |                        | m |          |
|        |               |       |                        | o |          |
|        |               |       |                        | u |          |
|        |               |       |                        | n |          |
|        |               |       |                        | t |          |
|        |               |       |                        | * |          |
|        |               |       |                        | * |          |
+--------+---------------+-------+------------------------+---+----------+
| #      |               |       |                        |   |          |
| # *Dep |               |       |                        |   |          |
| artmen |               |       |                        |   |          |
| t Audi |               |       |                        |   |          |
| ts* {# |               |       |                        |   |          |
| depart |               |       |                        |   |          |
| ment-a |               |       |                        |   |          |
| udits  |               |       |                        |   |          |
| .unnum |               |       |                        |   |          |
| bered} |               |       |                        |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | Talent Search | 02/   | The report stated that |   | \$0      |
| 7E0009 | Program at    | 16/05 | the TRIO Office did    |   |          |
|        | the U.S.      |       | not maintain           |   |          |
|        | Department of |       | sufficient internal    |   |          |
|        | Education     |       | control over Talent    |   |          |
|        |               |       | Search participant     |   |          |
|        |               |       | numbers because it did |   |          |
|        |               |       | not (i) properly       |   |          |
|        |               |       | maintain the records   |   |          |
|        |               |       | and procedures needed  |   |          |
|        |               |       | to readily determine   |   |          |
|        |               |       | the correct number of  |   |          |
|        |               |       | participants planned   |   |          |
|        |               |       | or (ii) provide the    |   |          |
|        |               |       | monitoring and policy  |   |          |
|        |               |       | guidance needed to     |   |          |
|        |               |       | insure accurate        |   |          |
|        |               |       | reporting of           |   |          |
|        |               |       | participants served.   |   |          |
|        |               |       | It was found that the  |   |          |
|        |               |       | Department might be    |   |          |
|        |               |       | using overstated       |   |          |
|        |               |       | Talent Search          |   |          |
|        |               |       | participant numbers    |   |          |
|        |               |       | for assessing grant    |   |          |
|        |               |       | performances and       |   |          |
|        |               |       | reporting to Congress  |   |          |
|        |               |       | and the general        |   |          |
|        |               |       | public.                |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | Audit of      | 06/   | The GEAR UP audit      |   | \$0      |
| 7A0033 | Gaining Early | 07/02 | report found that the  |   |          |
|        | Awareness and |       | program did not        |   |          |
|        | Readiness for |       | establish and follow   |   |          |
|        | Undergraduate |       | management controls    |   |          |
|        | Programs      |       | necessary to assure    |   |          |
|        |               |       | that it administered   |   |          |
|        |               |       | the program in         |   |          |
|        |               |       | accordance with        |   |          |
|        |               |       | legislative,           |   |          |
|        |               |       | regulatory and         |   |          |
|        |               |       | internal               |   |          |
|        |               |       | administrative         |   |          |
|        |               |       | requirements.          |   |          |
|        |               |       | Specifically, the      |   |          |
|        |               |       | audit found that the   |   |          |
|        |               |       | Department did not     |   |          |
|        |               |       | assure that: GEAR UP   |   |          |
|        |               |       | officials informed     |   |          |
|        |               |       | GPOS when changes were |   |          |
|        |               |       | made with GEAR UP      |   |          |
|        |               |       | program staff and      |   |          |
|        |               |       | officials holding      |   |          |
|        |               |       | warranty 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.           |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | Department    | 01/   | The audit disclosed    |   | \$0      |
| 790034 | Controls Over | 04/02 | that the Department    |   |          |
|        | TRIO Grantee  |       | needs to improve its   |   |          |
|        | Monitoring    |       | oversight of TRIO      |   |          |
|        |               |       | grantees.              |   |          |
|        |               |       | Specifically, the      |   |          |
|        |               |       | Department needs to    |   |          |
|        |               |       | ensure that 1) TRIO    |   |          |
|        |               |       | grantees are           |   |          |
|        |               |       | effectively monitored  |   |          |
|        |               |       | for compliance with    |   |          |
|        |               |       | federal requirements,  |   |          |
|        |               |       | 2) internal controls   |   |          |
|        |               |       | are strengthened to    |   |          |
|        |               |       | help prevent program   |   |          |
|        |               |       | abuse, resolve         |   |          |
|        |               |       | compliance problems,   |   |          |
|        |               |       | and enforce corrective |   |          |
|        |               |       | actions, and 3)        |   |          |
|        |               |       | reporting instructions |   |          |
|        |               |       | are clarified to       |   |          |
|        |               |       | ensure the integrity   |   |          |
|        |               |       | of national            |   |          |
|        |               |       | performance            |   |          |
|        |               |       | information.           |   |          |
+--------+---------------+-------+------------------------+---+----------+
| ##     |               |       |                        |   |          |
| # *Gra |               |       |                        |   |          |
| ntee A |               |       |                        |   |          |
| udits* |               |       |                        |   |          |
|  {#gra |               |       |                        |   |          |
| ntee-a |               |       |                        |   |          |
| udits  |               |       |                        |   |          |
| .unnum |               |       |                        |   |          |
| bered} |               |       |                        |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | University of | 12/   | The audit disclosed    |   | \        |
| 5D0041 | Illinois at   | 20/04 | that UIC               |   | $223,057 |
|        | Chicago's     |       | misrepresented the     |   |          |
|        | Upward Bound  |       | achievement of the     |   |          |
|        | Project       |       | Upward Bound project's |   |          |
|        |               |       | objectives because it  |   |          |
|        |               |       | did not have           |   |          |
|        |               |       | documentation          |   |          |
|        |               |       | supporting the         |   |          |
|        |               |       | achievements as        |   |          |
|        |               |       | reported to the        |   |          |
|        |               |       | Department. In         |   |          |
|        |               |       | addition, UIC (1) did  |   |          |
|        |               |       | not serve only         |   |          |
|        |               |       | ineligible             |   |          |
|        |               |       | participants, (2) did  |   |          |
|        |               |       | not appropriately      |   |          |
|        |               |       | account for grant      |   |          |
|        |               |       | funds, (3) could not   |   |          |
|        |               |       | support all of its     |   |          |
|        |               |       | expenditures, and (4)  |   |          |
|        |               |       | charged unallowable    |   |          |
|        |               |       | costs to the grant.    |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | The           | 01/   | The audit disclosed    |   | \$1      |
| 5D0017 | University of | 14/04 | that UIC did not       |   | ,018,212 |
|        | Illinois at   |       | comply with the terms  |   |          |
|        | Chicago's     |       | of its agreement with  |   |          |
|        | Gaining Early |       | the Department. UIC    |   |          |
|        | Awareness and |       | failed to show that    |   |          |
|        | Readiness for |       | its GEAR UP project    |   |          |
|        | Undergraduate |       | provided services to   |   |          |
|        | Programs      |       | 1,130 participants     |   |          |
|        | Project       |       | from its cohort during |   |          |
|        |               |       | each of the first      |   |          |
|        |               |       | three years of the     |   |          |
|        |               |       | grant (September 1,    |   |          |
|        |               |       | 1999, through August   |   |          |
|        |               |       | 31, 2002). In          |   |          |
|        |               |       | addition, UIC and its  |   |          |
|        |               |       | partnership failed to  |   |          |
|        |               |       | provide \$990,847 in   |   |          |
|        |               |       | required non-federal   |   |          |
|        |               |       | matching contributions |   |          |
|        |               |       | for the first three    |   |          |
|        |               |       | years of the grant.    |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | New Orleans   | 10/   | New Orleans            |   | \$1      |
| 6D0015 | Educational   | 21/04 | Educational Talent     |   | ,937,980 |
|        | Talent Search |       | Search Program, Inc.,  |   |          |
|        | Program, Inc  |       | materially failed to   |   |          |
|        |               |       | comply with the Higher |   |          |
|        |               |       | Education Act of 1965  |   |          |
|        |               |       | (HEA), as amended,     |   |          |
|        |               |       | regulations governing  |   |          |
|        |               |       | the Talent Search      |   |          |
|        |               |       | Program, and its       |   |          |
|        |               |       | approved grant         |   |          |
|        |               |       | application. During    |   |          |
|        |               |       | the period September   |   |          |
|        |               |       | 1, 1998, through       |   |          |
|        |               |       | December 31, 2002,     |   |          |
|        |               |       | NOETSP did not (1)     |   |          |
|        |               |       | comply with the grant  |   |          |
|        |               |       | performance            |   |          |
|        |               |       | requirements, and (2)  |   |          |
|        |               |       | properly account for   |   |          |
|        |               |       | \$1,937,980 in Talent  |   |          |
|        |               |       | Search Program funds.  |   |          |
|        |               |       | Specifically, NOETSP   |   |          |
|        |               |       | did not (1) document   |   |          |
|        |               |       | needs assessments for  |   |          |
|        |               |       | its participants,      |   |          |
|        |               |       | including whether the  |   |          |
|        |               |       | students were          |   |          |
|        |               |       | low-income or          |   |          |
|        |               |       | prospective            |   |          |
|        |               |       | first-generation       |   |          |
|        |               |       | college students, and  |   |          |
|        |               |       | (2) maintain a record  |   |          |
|        |               |       | of services provided   |   |          |
|        |               |       | and educational        |   |          |
|        |               |       | progress made by each  |   |          |
|        |               |       | participant as a       |   |          |
|        |               |       | result of the          |   |          |
|        |               |       | services.              |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | Stillman      | 10/   | The audit covered the  |   | \        |
| 4C0019 | College's     | 15/03 | following TRIO         |   | $313,545 |
|        | A             |       | programs; Student      |   |          |
|        | dministration |       | Support Services       |   |          |
|        | of the        |       | (SSS), Upward Bound    |   |          |
|        | Federal TRIO  |       | (UB), Upward Bound     |   |          |
|        | Programs      |       | Young Scholars (UBYS), |   |          |
|        | Needs         |       | and Upward Bound Math  |   |          |
|        | Improvement   |       | & Science (UBMS). The  |   |          |
|        |               |       | audit found that the   |   |          |
|        |               |       | college: 1) had drawn  |   |          |
|        |               |       | down TRIO funds in     |   |          |
|        |               |       | excess of its program  |   |          |
|        |               |       | expenditures totaling  |   |          |
|        |               |       | \$313,545 for three    |   |          |
|        |               |       | TRIO programs (SSS,    |   |          |
|        |               |       | UBYS, and UBMS); 2)    |   |          |
|        |               |       | lacked proper          |   |          |
|        |               |       | accounting controls    |   |          |
|        |               |       | over recording and     |   |          |
|        |               |       | reporting TRIO program |   |          |
|        |               |       | expenditures and       |   |          |
|        |               |       | reporting expenditures |   |          |
|        |               |       | in the financial       |   |          |
|        |               |       | statements; 3) did not |   |          |
|        |               |       | maintain an adequate   |   |          |
|        |               |       | inventory of computer  |   |          |
|        |               |       | equipment purchased    |   |          |
|        |               |       | with TRIO funds, and   |   |          |
|        |               |       | 4) SSS program         |   |          |
|        |               |       | services were provided |   |          |
|        |               |       | to non-SSS             |   |          |
|        |               |       | participants.          |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | Audit of the  | 03/   | Luther College did not |   | \        |
| 7C0031 | Talent Search | 28/03 | always administer its  |   | $219,567 |
|        | Program at    |       | Federal Talent Search  |   |          |
|        | Luther        |       | grant in accordance    |   |          |
|        | College       |       | with applicable law    |   |          |
|        |               |       | and regulations. For   |   |          |
|        |               |       | the grant period       |   |          |
|        |               |       | September 1, 2001,     |   |          |
|        |               |       | through August 31,     |   |          |
|        |               |       | 2002, it was estimated |   |          |
|        |               |       | that Luther College    |   |          |
|        |               |       | served only 363 of the |   |          |
|        |               |       | 625 participants it    |   |          |
|        |               |       | was funded to serve,   |   |          |
|        |               |       | which is significantly |   |          |
|        |               |       | less than the 600      |   |          |
|        |               |       | participants required  |   |          |
|        |               |       | of Talent Search       |   |          |
|        |               |       | grantees.              |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | The Talent    | 01/   | The University did not |   | \$0      |
| 7D0001 | Search        | 15/04 | always administer its  |   |          |
|        | Program at    |       | Talent Search grant in |   |          |
|        | the           |       | accordance with        |   |          |
|        | University of |       | applicable regulations |   |          |
|        | New Hampshire |       | or its Departmental    |   |          |
|        |               |       | agreement. The         |   |          |
|        |               |       | University could not   |   |          |
|        |               |       | provide documentation  |   |          |
|        |               |       | for all services it    |   |          |
|        |               |       | claims to have         |   |          |
|        |               |       | provided to            |   |          |
|        |               |       | participants. For the  |   |          |
|        |               |       | grant period September |   |          |
|        |               |       | 1, 2001, through       |   |          |
|        |               |       | August 31, 2002, we    |   |          |
|        |               |       | estimated that the     |   |          |
|        |               |       | University might have  |   |          |
|        |               |       | served fewer than the  |   |          |
|        |               |       | 1,150 participants it  |   |          |
|        |               |       | was funded to serve.   |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | The Talent    | 11/   | Wahupa did not always  |   | \        |
| 7D0009 | Search        | 25/03 | administer its Talent  |   | $122,900 |
|        | Program at    |       | Search grant in        |   |          |
|        | Wahupa        |       | accordance with        |   |          |
|        | Educational   |       | applicable law and     |   |          |
|        | Services      |       | regulations. For the   |   |          |
|        |               |       | grant period September |   |          |
|        |               |       | 1, 2001, through       |   |          |
|        |               |       | August 31, 2002, it    |   |          |
|        |               |       | was estimated that     |   |          |
|        |               |       | Wahupa served 1,702\   |   |          |
|        |               |       | allowable participants |   |          |
|        |               |       | of the 2,300           |   |          |
|        |               |       | participants it was    |   |          |
|        |               |       | funded to serve.       |   |          |
|        |               |       | Wahupa did not serve   |   |          |
|        |               |       | the participant number |   |          |
|        |               |       | it reported on the     |   |          |
|        |               |       | APR, and less than     |   |          |
|        |               |       | two-thirds of its      |   |          |
|        |               |       | Talent Search          |   |          |
|        |               |       | participants were      |   |          |
|        |               |       | low-income individuals |   |          |
|        |               |       | who were potential     |   |          |
|        |               |       | first-generation       |   |          |
|        |               |       | college students.      |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | The Talent    | 01/   | CIS did not fully      |   | \        |
| 7D0015 | Search        | 29/04 | comply with the HEA    |   | $298,349 |
|        | Program at    |       | and specific           |   |          |
|        | Communities   |       | regulations or follow  |   |          |
|        | in Schools of |       | its own grant proposal |   |          |
|        | San Antonio   |       | in meeting its target  |   |          |
|        |               |       | population. The grant  |   |          |
|        |               |       | project did not serve  |   |          |
|        |               |       | the minimum required   |   |          |
|        |               |       | (600) participant      |   |          |
|        |               |       | population for an      |   |          |
|        |               |       | eligible Talent Search |   |          |
|        |               |       | program. For the       |   |          |
|        |               |       | September 1, 2001,     |   |          |
|        |               |       | through August 31,     |   |          |
|        |               |       | 2002, budget period,   |   |          |
|        |               |       | it was estimated that  |   |          |
|        |               |       | out of the 601         |   |          |
|        |               |       | participants claimed   |   |          |
|        |               |       | as served, only 481    |   |          |
|        |               |       | were allowable         |   |          |
|        |               |       | participants.          |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | Talent Search | 06/   | LNESC did not always   |   | \$0      |
| 7D0024 | Program at    | 18/04 | administer its grant   |   |          |
|        | LULAC         |       | in accordance with the |   |          |
|        | National      |       | law and regulation     |   |          |
|        | Educational   |       | governing the          |   |          |
|        | Service       |       | documentation of       |   |          |
|        | Centers, Inc. |       | participant            |   |          |
|        |               |       | eligibility. As a      |   |          |
|        |               |       | result, LNESC          |   |          |
|        |               |       | overstated Talent      |   |          |
|        |               |       | Search participants    |   |          |
|        |               |       | served in its APR      |   |          |
|        |               |       | submitted to the       |   |          |
|        |               |       | Department for the     |   |          |
|        |               |       | September 1, 2001,     |   |          |
|        |               |       | through August 31,     |   |          |
|        |               |       | 2002, budget period.   |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | The Talent    | 07/   | Case Western Reserve   |   | \        |
| 7D0002 | Search        | 11/03 | University did not     |   | $212,428 |
|        | Program at    |       | always administer its  |   |          |
|        | Case Western  |       | Federal Talent Search  |   |          |
|        | Reserve       |       | grant in accordance    |   |          |
|        | University    |       | with applicable law    |   |          |
|        |               |       | and regulations. For   |   |          |
|        |               |       | the grant period       |   |          |
|        |               |       | September 1, 2001,     |   |          |
|        |               |       | through August 31,     |   |          |
|        |               |       | 2002, we estimate that |   |          |
|        |               |       | CWRU served only 399   |   |          |
|        |               |       | of the 600             |   |          |
|        |               |       | participants, the      |   |          |
|        |               |       | minimum number of      |   |          |
|        |               |       | participants required  |   |          |
|        |               |       | of TA grantees, it was |   |          |
|        |               |       | funded to serve.       |   |          |
+--------+---------------+-------+------------------------+---+----------+
| X0     | State         | 09/   | It was found that none |   | \$0      |
| 6D0021 | Education     | 30/03 | of the four States (1) |   |          |
|        | Agencies      |       | established and        |   |          |
|        | (Texas,       |       | implemented            |   |          |
|        | Florida,      |       | appropriate procedures |   |          |
|        | Kansas, and   |       | to identify and target |   |          |
|        | California)   |       | services to migratory  |   |          |
|        | and their     |       | children who are       |   |          |
|        | sub-grantees, |       | failing, or most at    |   |          |
|        | and to        |       | risk of failing, to    |   |          |
|        | identify how  |       | meet State standards,  |   |          |
|        | the Office of |       | and whose education    |   |          |
|        | Migrant       |       | was interrupted during |   |          |
|        | Education can |       | the regular school     |   |          |
|        | improve the   |       | year, and (2)          |   |          |
|        | Migrant       |       | established procedures |   |          |
|        | Education     |       | to report to the       |   |          |
|        | Program       |       | Department an accurate |   |          |
|        |               |       | number of "Priority    |   |          |
|        |               |       | for Services"          |   |          |
|        |               |       | migratory children     |   |          |
|        |               |       | served. As a result,   |   |          |
|        |               |       | the Department could   |   |          |
|        |               |       | not determine whether  |   |          |
|        |               |       | the \$212.2 million in |   |          |
|        |               |       | Migrant Education      |   |          |
|        |               |       | Program funds received |   |          |
|        |               |       | by these four States   |   |          |
|        |               |       | in FY 2001 were used   |   |          |
|        |               |       | to provide services to |   |          |
|        |               |       | Priority for Services  |   |          |
|        |               |       | migratory children     |   |          |
|        |               |       | before services were   |   |          |
|        |               |       | provided to other      |   |          |
|        |               |       | migratory children.    |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | Future        | 03/   | The audit disclosed    |   | \        |
| 5D0037 | Teachers of   | 23/04 | that Future Teachers   |   | $365,296 |
|        | Chicago,      |       | did not expend grant   |   |          |
|        | Illinois      |       | funds in accordance    |   |          |
|        | Teacher       |       | with Title II of the   |   |          |
|        | Recruitment   |       | Higher Education Act   |   |          |
|        | Grant         |       | of 1965, as amended,   |   |          |
|        |               |       | applicable             |   |          |
|        |               |       | regulations, and terms |   |          |
|        |               |       | of the Grant award.    |   |          |
|        |               |       | Future Teachers lacked |   |          |
|        |               |       | the ability to         |   |          |
|        |               |       | adequately administer  |   |          |
|        |               |       | the grant because it   |   |          |
|        |               |       | was not familiar with  |   |          |
|        |               |       | program requirements   |   |          |
|        |               |       | and, as a result, did  |   |          |
|        |               |       | not establish or       |   |          |
|        |               |       | implement an adequate  |   |          |
|        |               |       | financial management   |   |          |
|        |               |       | system and adequate    |   |          |
|        |               |       | management controls.   |   |          |
|        |               |       | During the period      |   |          |
|        |               |       | October 1, 2002,       |   |          |
|        |               |       | through June 30, 2003, |   |          |
|        |               |       | Future Teachers        |   |          |
|        |               |       | charged the Grant for  |   |          |
|        |               |       | costs it did not       |   |          |
|        |               |       | adequately support and |   |          |
|        |               |       | for unallowable costs, |   |          |
|        |               |       | and maintained excess  |   |          |
|        |               |       | cash.                  |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | The Dallas    | 09/   | The audit disclosed    |   | \        |
| 6E0015 | Independent   | 16/04 | that although DISD     |   | $205,000 |
|        | School        |       | properly accounted for |   |          |
|        | District's    |       | and used grant funds   |   |          |
|        | (DISD)        |       | in accordance with     |   |          |
|        | a             |       | applicable federal     |   |          |
|        | dministration |       | laws, regulations,     |   |          |
|        | of the        |       | grant terms, and cost  |   |          |
|        | Teaching      |       | principles during the  |   |          |
|        | American      |       | first two years of the |   |          |
|        | History Grant |       | grant, DISD did not    |   |          |
|        |               |       | obtain the required    |   |          |
|        |               |       | prior approval for a   |   |          |
|        |               |       | change in key          |   |          |
|        |               |       | personnel for the      |   |          |
|        |               |       | approved grant.        |   |          |
|        |               |       | Consequently, DISD     |   |          |
|        |               |       | disbursed \$205,000 in |   |          |
|        |               |       | grant funds to the new |   |          |
|        |               |       | unapproved and,        |   |          |
|        |               |       | therefore, ineligible  |   |          |
|        |               |       | grant partner.         |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | The           | 12/   | The audit disclosed    |   | \        |
| 5E0002 | University of | 15/04 | that UIC (1) failed to |   | $260,050 |
|        | Illinois at   |       | provide evidence of    |   |          |
|        | Chicago's     |       | fulfillment of         |   |          |
|        | (UIC) Student |       | assurances, (2) did    |   |          |
|        | Support       |       | not accurately report  |   |          |
|        | Services      |       | the accomplishments of |   |          |
|        | program       |       | its SSS program to the |   |          |
|        |               |       | Department, (3)        |   |          |
|        |               |       | charged unallowable    |   |          |
|        |               |       | costs to the grant,    |   |          |
|        |               |       | and (4) could not      |   |          |
|        |               |       | support all of its     |   |          |
|        |               |       | personnel              |   |          |
|        |               |       | expenditures.          |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | Stillman      | 12/   | The audit found that   |   | \$76,151 |
| 4D0013 | College's     | 30/03 | the College drew down  |   |          |
|        | A             |       | more Title III funds   |   |          |
|        | dministration |       | than it expended for   |   |          |
|        | of the Title  |       | program activities and |   |          |
|        | III, Part B,  |       | did not inform the     |   |          |
|        | Strengthening |       | Department of changes  |   |          |
|        | Historically  |       | in key personnel.      |   |          |
|        | Black         |       |                        |   |          |
|        | Colleges and  |       |                        |   |          |
|        | Universities  |       |                        |   |          |
|        | Program       |       |                        |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | Kentucky      | 03/   | KSU generally met the  |   | \$28,083 |
| 4C0014 | State         | 12/03 | Title III, Part B,     |   |          |
|        | University's  |       | cash management        |   |          |
|        | A             |       | requirements, but it   |   |          |
|        | dministration |       | did not always meet    |   |          |
|        | of the Title  |       | the record keeping     |   |          |
|        | III, Part B,  |       | requirements for grant |   |          |
|        | Strengthening |       | expenditures. KSU      |   |          |
|        | Historically  |       | accounting controls    |   |          |
|        | Black         |       | did not always ensure  |   |          |
|        | Colleges and  |       | that grant             |   |          |
|        | Universities  |       | expenditures were      |   |          |
|        | Program       |       | fully documented and   |   |          |
|        |               |       | supported.             |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | College of    | 04/   | The objective of the   |   | \$0      |
| 5F0011 | Lake County   | 04/05 | audit was to determine |   |          |
|        | Community     |       | if the College         |   |          |
|        | College       |       | expended Federal       |   |          |
|        | District No.  |       | Strengthening          |   |          |
|        | 532 (College) |       | Institutions grant     |   |          |
|        | Strengthening |       | funds in accordance    |   |          |
|        | Institutions  |       | with its grant         |   |          |
|        | grant funds   |       | agreement, federal law |   |          |
|        |               |       | and regulations, and   |   |          |
|        |               |       | applicable cost        |   |          |
|        |               |       | principles for the two |   |          |
|        |               |       | years ended September  |   |          |
|        |               |       | 30, 2004. There were   |   |          |
|        |               |       | no findings that       |   |          |
|        |               |       | required resolution.   |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | Governors     | 08/   | The audit disclosed    |   | \$3,213  |
| 5C0028 | State         | 18/03 | that GSU 1) operated a |   |          |
|        | University's  |       | financial management   |   |          |
|        | (GSU)         |       | system that was        |   |          |
|        | a             |       | inadequate to          |   |          |
|        | dministration |       | completely and         |   |          |
|        | of its        |       | accurately account for |   |          |
|        | Student       |       | Student Support        |   |          |
|        | Support       |       | Services and Upward    |   |          |
|        | Services and  |       | Bound funds and        |   |          |
|        | Upward Bound  |       | inadequate to compare  |   |          |
|        | programs      |       | outlays with approved  |   |          |
|        |               |       | budgeted amounts for   |   |          |
|        |               |       | each award year, 2)    |   |          |
|        |               |       | did not accurately     |   |          |
|        |               |       | report the             |   |          |
|        |               |       | accomplishments of its |   |          |
|        |               |       | Student Support        |   |          |
|        |               |       | Services and Upward    |   |          |
|        |               |       | Bound programs, 3) did |   |          |
|        |               |       | not maintain adequate  |   |          |
|        |               |       | support for all        |   |          |
|        |               |       | Student Support        |   |          |
|        |               |       | Services and Upward    |   |          |
|        |               |       | Bound expenses, and 4) |   |          |
|        |               |       | incorrectly calculated |   |          |
|        |               |       | indirect costs.        |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | University of | 12/   | The audit disclosed    |   | \        |
| 5E0018 | Illinois at   | 17/04 | that UIC               |   | $274,493 |
|        | Chicago's     |       | misrepresented its     |   |          |
|        | (UIC) Upward  |       | UBMS project's         |   |          |
|        | Bound Math    |       | accomplishments to the |   |          |
|        | and Science   |       | Department. UIC did    |   |          |
|        | (UBMS)        |       | not maintain           |   |          |
|        | project       |       | documentation          |   |          |
|        |               |       | supporting that it     |   |          |
|        |               |       | achieved the project's |   |          |
|        |               |       | objectives as reported |   |          |
|        |               |       | to the Department,     |   |          |
|        |               |       | served ineligible      |   |          |
|        |               |       | participants and did   |   |          |
|        |               |       | not provide all        |   |          |
|        |               |       | required services, did |   |          |
|        |               |       | not appropriately      |   |          |
|        |               |       | account for grant      |   |          |
|        |               |       | funds, could not       |   |          |
|        |               |       | support all its        |   |          |
|        |               |       | expenditures, and      |   |          |
|        |               |       | charged unallowable    |   |          |
|        |               |       | costs to the grant.    |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | Magdalena     | 03/   | Magdalena did not      |   | \$21,763 |
| 6D0027 | Municipal     | 30/04 | properly account for   |   |          |
|        | Schools'      |       | and use GEAR UP        |   |          |
|        | (Magdalena)   |       | partnership grant      |   |          |
|        | a             |       | funds in accordance    |   |          |
|        | dministration |       | with all applicable    |   |          |
|        | of the        |       | regulations, grant     |   |          |
|        | Gaining Early |       | terms, and cost        |   |          |
|        | Awareness and |       | principles.            |   |          |
|        | Readiness for |       | Specifically,          |   |          |
|        | Undergraduate |       | Magdalena awarded GEAR |   |          |
|        | Programs      |       | UP scholarships to     |   |          |
|        | (GEAR UP)     |       | ineligible students,   |   |          |
|        | grant         |       | charged the grant for  |   |          |
|        |               |       | fund raising costs,    |   |          |
|        |               |       | used grant funds for   |   |          |
|        |               |       | expenditures that were |   |          |
|        |               |       | not adequately         |   |          |
|        |               |       | supported, and did not |   |          |
|        |               |       | establish a separate   |   |          |
|        |               |       | trust fund to          |   |          |
|        |               |       | safeguard GEAR UP      |   |          |
|        |               |       | scholarship funds.     |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | California    | 06/   | The Foundation did not |   | \        |
| 9D0032 | State         | 17/04 | meet the required      |   | $380,400 |
|        | University,   |       | matching contributions |   |          |
|        | Fresno        |       | for any of the four    |   |          |
|        | Foundation's  |       | years covered by the   |   |          |
|        | A             |       | review because the     |   |          |
|        | dministration |       | Foundation did not     |   |          |
|        | of GEAR UP    |       | have the required      |   |          |
|        | Partnership   |       | documentation for the  |   |          |
|        | Grant         |       | claimed contributions. |   |          |
|        |               |       | Further, the           |   |          |
|        |               |       | Foundation did not use |   |          |
|        |               |       | and properly account   |   |          |
|        |               |       | for the GEAR UP grant  |   |          |
|        |               |       | funds in accordance    |   |          |
|        |               |       | with federal           |   |          |
|        |               |       | regulations.           |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | Audit of      | 05/   | The audit found that   |   | \$1      |
| 7B0011 | Valencia      | 08/03 | VCC officials did not  |   | ,822,864 |
|        | Community     |       | administer its GEAR UP |   |          |
|        | College's     |       | projects in accordance |   |          |
|        | Gaining Early |       | with legislative,      |   |          |
|        | Awareness and |       | regulatory, and        |   |          |
|        | Readiness for |       | administrative         |   |          |
|        | Undergraduate |       | requirements for       |   |          |
|        | Programs      |       | non-federal match.     |   |          |
|        | Matching      |       | Further, VCC did not   |   |          |
|        | Requirement   |       | maintain adequate      |   |          |
|        |               |       | documentation to       |   |          |
|        |               |       | support the required   |   |          |
|        |               |       | match, claimed         |   |          |
|        |               |       | facilities and         |   |          |
|        |               |       | equipment costs were   |   |          |
|        |               |       | improperly calculated, |   |          |
|        |               |       | and matching claims    |   |          |
|        |               |       | included unallowable,  |   |          |
|        |               |       | unallocable, and       |   |          |
|        |               |       | unreasonable room      |   |          |
|        |               |       | usages.                |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | Audit of      | 07/   | The University did     |   | \$0      |
| 9B0026 | Delaware      | 11/02 | not 1) promptly        |   |          |
|        | State         |       | account for HBCU       |   |          |
|        | University's  |       | Program funds drawn    |   |          |
|        | A             |       | down for the Endowment |   |          |
|        | dministration |       | Challenge Program      |   |          |
|        | of the Title  |       | activity, 2) promptly  |   |          |
|        | III           |       | provide matching funds |   |          |
|        | Strengthening |       | for the HBCU Program   |   |          |
|        | HBCU Program  |       | funds, and 3) deposit  |   |          |
|        |               |       | and invest the         |   |          |
|        |               |       | endowment fund corpus  |   |          |
|        |               |       | in a timely manner. In |   |          |
|        |               |       | addition, the          |   |          |
|        |               |       | University reported    |   |          |
|        |               |       | inaccurate information |   |          |
|        |               |       | on the status of the   |   |          |
|        |               |       | Endowment Challenge    |   |          |
|        |               |       | Program activity to    |   |          |
|        |               |       | the Department in its  |   |          |
|        |               |       | continuation grant     |   |          |
|        |               |       | applications and       |   |          |
|        |               |       | annual performance     |   |          |
|        |               |       | reports. Further, the  |   |          |
|        |               |       | University did not     |   |          |
|        |               |       | adequately account for |   |          |
|        |               |       | the endowment funds    |   |          |
|        |               |       | established with Title |   |          |
|        |               |       | III HBCU Program and   |   |          |
|        |               |       | Endowment Challenge    |   |          |
|        |               |       | Grant Program funds.   |   |          |
|        |               |       | Lastly, the University |   |          |
|        |               |       | charged unallowable    |   |          |
|        |               |       | and unsupported costs  |   |          |
|        |               |       | to the program.        |   |          |
+--------+---------------+-------+------------------------+---+----------+
| A0     | North Alabama | 11/   | NACEE violated the     |   | \        |
| 4D0001 | Center for    | 24/03 | conflict of interest   |   | $877,384 |
|        | Educational   |       | regulations regarding  |   |          |
|        | Excellence's  |       | payment for rental     |   |          |
|        | A             |       | space at its central   |   |          |
|        | dministration |       | office, used TRIO      |   |          |
|        | of the TRIO   |       | funds to pay           |   |          |
|        | Programs      |       | performance awards to  |   |          |
|        | Needs         |       | employees without an   |   |          |
|        | Improvement   |       | established            |   |          |
|        |               |       | institutional award    |   |          |
|        |               |       | plan, lacked           |   |          |
|        |               |       | documentation for one  |   |          |
|        |               |       | expenditure, failed to |   |          |
|        |               |       | maintain activity      |   |          |
|        |               |       | reports to support the |   |          |
|        |               |       | Executive Director's   |   |          |
|        |               |       | TRIO salary            |   |          |
|        |               |       | distribution, and did  |   |          |
|        |               |       | not adequately support |   |          |
|        |               |       | TRIO program           |   |          |
|        |               |       | achievements reported  |   |          |
|        |               |       | in the 2000-2001 and   |   |          |
|        |               |       | 2001-2002 performance  |   |          |
|        |               |       | reports.               |   |          |
+--------+---------------+-------+------------------------+---+----------+

**[Attachment C]{.underline}**

**Auditee Response**

February 10, 2006

Ms. Helen Lew

Assistant Inspector General for Audit Services

Office of the Inspector General

U.S. Department of Education

400 Maryland Avenue, SW

Washington, DC 20202

Dear Ms. Lew:

Thank you for the opportunity to comment on the Office of Inspector
General's (OIG's) Draft Management Information Report, "Overlapping
Services in the Department of Education's Office of Postsecondary
Education Programs," (ED-OIG/X07F0002) dated December 29, 2005. The
objectives of the review were to determine: 1) if Office of
Postsecondary Education (OPE) grant programs have duplicative program
objectives aimed at serving like target populations and areas; and 2) if
grant programs administered by other U.S. Department of Education
(Department) offices contain program objectives that overlap with those
of OPE grant programs.

The report summarizes the results of the audit of 42 discretionary and
formula grant programs administered by OPE and funded in FY 2003-2004,
which OIG believes may overlap in some way with 15 Office of Vocational
and Adult Education (OVAE) and 13 Office of Elementary and Secondary
Education (OESE) grant programs. The Department concurs with the
report's finding that some of the 42 programs reviewed by OIG overlap
with or are duplicative of other Department programs and should be
reformed or eliminated. Indeed, the President's budget has proposed to
replace a number of the programs that are directed at preparing students
for postsecondary education with a more comprehensive approach to
improving high school education and has included other recommendations
for eliminating other duplicative programs. As noted below, the
Department has also made some organizational changes that should
facilitate management of similar programs. Further analysis and
discussion are needed to determine whether there are other options that
should be considered for enhancing program administration through
reorganization or better coordination.

In the following paragraphs, the Department would like to respond
directly to the specific recommendations in this report:

1.  Consider working with Congress to consolidate or eliminate programs
    that have the same or similar program objectives.\
    \
    The Department concurs with this suggestion and, for a number of
    years, the Administration had proposed elimination of duplicative or
    otherwise unneeded programs. In the fiscal year 2006 budget request,
    we recommended elimination of 48 Department programs, and Congress
    responded by eliminating funding for five of them. In the newly
    announced fiscal year 2007 budget, we recommended the elimination of
    42 programs. Proposed terminations included B.J. Stupak Olympic
    Scholarships, Byrd Honors Scholarships, Teacher Quality Enhancement,
    Demonstration Projects to Ensure Students with Disabilities Receive
    a Quality Higher Education, and Thurgood Marshall Legal Educational
    Opportunity programs, which are administered by OPE, and the
    Enhancing Education Through Technology Program, which is
    administered by OESE, because they are duplicative of other
    programs. Other programs were also proposed for elimination because
    they would be replaced by the more comprehensive High School Reform
    initiative. These programs included Gaining Early Awareness and
    Readiness for Undergraduate Programs (GEAR UP), the TRIO Talent
    Search Program, TRIO Upward Bound, and TRIO Upward Bound
    Math/Science, which are administered by OPE, and the Vocational
    Education State Grants, Vocational Education Grants to Native
    Americans and Alaskan Natives, and Vocational Education \-- Native
    Hawaiians programs, which are administered by OVAE. In addition, the
    Administration previously proposed the elimination of the Preparing
    for Tomorrow's Teachers to Use Technology program, and Congress
    terminated funding.\
    \
    The Department continues to conduct reviews on various programs
    using the Office of Management and Budget\'s Program Assessment
    Rating Tool. This process continues to serve as a mechanism for the
    Department to examine the effectiveness of its programs and consider
    opportunities for the consolidation and elimination of programs,
    taking into account Administration priorities and data regarding
    program effectiveness.

2.  **Consider realigning similar grant programs to be administered by
    the same office within the Department.\
    \
    **The Department concurs, in general, with this suggestion and
    continues to assess program goals and objectives, realigning similar
    programs when appropriate. However, the Department does not believe
    that realigning program staff at the present time would necessarily
    increase efficiency of its operations. In 2005, the Department
    reorganized to streamline the agency's functions, clarify roles and
    responsibilities, and integrate policy development, program
    implementation, and communication. This should assist the Department
    as it reviews its grant programs for additional opportunities to
    increase efficiency and effectiveness.\
    \
    To promote coordination among OPE programs, all but one of the
    higher education grant programs are administered under the Deputy
    Assistant Secretary for Higher Education Programs (HEP). The HEP
    office coordinates program policy, planning, and implementation.
    Program managers and staff interact on a daily basis. Additionally,
    OPE has increased the use of electronic resources, such as the
    Grants.gov Web site, resulting in improved services and reduced
    burden on applicants.\
    \
    In addition, the Administration has requested funding for the
    Tribally-Controlled Postsecondary Vocational and Technical
    Institutions program, which is currently administered by OVAE, under
    OPE's Higher Education account and has recommended that Congress
    reauthorize the program as part of the Higher Education Act.

3.  **Consider improving coordination between OPE and other Department
    programs with the same or similar program objectives.\
    **The Department recognizes the benefits of coordination and
    routinely explores ways to strengthen coordination among various OPE
    programs with similar objectives that are administered by other
    program offices. For example, there has been extensive coordination
    between OPE and OESE on the issue of highly qualified teachers and
    the Secretary\'s annual reports under Title II of the Higher
    Education Act. One outcome of this cooperation has been the adoption
    of common performance measures for programs with comparable
    objectives.\
    \
    OPE administers 47 discretionary and formula grant programs that
    have a broad range of objectives, target populations, and grant
    recipients. OPE will continue its current efforts to look for
    opportunities to streamline programs, maximize electronic
    capabilities to reduce burden, and standardize program
    administration.

The Department will provide technical corrections and clarifications
separately for you to consider as you complete the final version of your
report. We hope that this response will further your efforts to support
the Department goals of improving the management of Federal resources
and strengthening overall accountability.

Sincerely,

> Raymond Simon David Dunn
>
> Deputy Secretary Acting Under Secretary

cc: Hudson La Force, Senior Counselor to the Secretary

Sally Stroup, Assistant Secretary, Office of Postsecondary Education

Henry Johnson, Assistant Secretary, Office of Elementary and Secondary

Education

Beto Gonzalez, Acting Assistant Secretary, Office of Vocational and
Adult

Education

[^1]: We only reviewed programs administered through OPE, OESE, and
    OVAE.

[^2]: See Attachment B for a listing.