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| Review of the Office of Postsecondary Education's Awarding of Prior   |
| Experience Points in the 2006 Educational Opportunity Centers and     |
| Talent Search                                                         |
|                                                                       |
| Grant Competitions                                                    |
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## FINAL INSPECTION REPORT

![](media/image1.pct)

**ED-OIG/I13I0001**

**September 2008**

+-------------------------+----------------------+---------------------+
| Our mission is to       | !                    | U.S Department of   |
| promote the efficiency, | [](media/image2.bmp) | Education           |
| effectiveness, and      |                      |                     |
| integrity of the        |                      | Office of Inspector |
| Department\'s programs  |                      | General             |
| and operations.         |                      |                     |
|                         |                      | Washington, D.C.    |
+-------------------------+----------------------+---------------------+

Statements that managerial practices need improvements, as well as other
conclusions and recommendations in this report, represent the opinions
of the Office of Inspector General. Determinations of corrective action
to be taken will be made by the appropriate Department of Education
officials.

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.

> ![](media/image3.pct){width="0.875in" height="0.875in"}**UNITED STATES
> DEPARTMENT OF EDUCATION**

OFFICE OF INSPECTOR GENERAL

September 8, 2008

##### Memorandum {#memorandum .Enclosure-Number}

**TO:** Cheryl Oldham

> Acting Assistant Secretary
>
> Office of Postsecondary Education

**FROM:** Wanda A. Scott /s/

> Assistant Inspector General
>
> Evaluation, Inspection, and Management Services

**SUBJECT:** Final Inspection Report

> Review of the Office of Postsecondary Education's Awarding of Prior
> Experience Points in the 2006 Educational Opportunity Centers and
> Talent Search Grant Competitions (Control Number ED-OIG/I13I0001)

Attached is the final inspection report of our Review of the Office of
Postsecondary Education's Awarding of Prior Experience Points in the
2006 Educational Opportunity Centers and Talent Search Grant
Competitions. We received your comments to our draft report on July 11,
2008. A copy of your response to the draft report in its entirety is
attached.

Corrective actions proposed (resolution phase) and implemented (closure
phase) will be monitored and tracked through the Department\'s Audit
Accountability and Resolution Tracking System (AARTS). Department policy
requires that you develop a proposed corrective action plan for our
review in the automated system within 30 days of the issuance of this
report. The corrective action plan should set forth the specific action
items, and targeted completion dates, necessary to implement final
corrective actions on the findings and recommendations contained in this
final inspection report.

In accordance with the Inspector General Act of 1978, as amended, the
Office of Inspector General is required to report to Congress twice a
year on the reports that remain unresolved after six months from the
date of issuance.

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 or
your staff have any questions, please contact Christopher Wilson, Acting
Assistant Director, Evaluation and Inspection Services at 202-245-7061.

Enclosure

TABLE OF CONTENTS

####### Page

[**EXECUTIVE SUMMARY 1**](#__RefHeading___Toc207157165)

[BACKGROUND 1](#__RefHeading___Toc207157166)

[INSPECTION RESULTS 1](#__RefHeading___Toc207157167)

[FINDING NO. 1 -- OPE's Awarding of Prior Experience Points was Not in
Compliance with the Regulations 1](#__RefHeading___Toc207157168)

[FINDING NO. 2 -- OPE Awarded Points to Grantees that Did Not Meet
Minimum Program Requirements 1](#__RefHeading___Toc207157169)

[FINDING NO. 3 -- OPE Made Errors in the Execution of its Prior
Experience Points Assessment 1](#__RefHeading___Toc207157170)

[FINDING NO. 4 -- OPE Changed its Process for Awarding Prior Experience
Points without Having the Appropriate Data to Evaluate Grantees
1](#__RefHeading___Toc207157171)

[DEPARTMENT COMMENTS 1](#__RefHeading___Toc207157172)

[OBJECTIVE, SCOPE, AND METHODOLOGY 1](#__RefHeading___Toc207157173)

[APPENDICES 1](#__RefHeading___Toc207157174)

[Appendix 1 Educational Opportunity Centers (EOC) Issues by Finding
(Sample of 20)
1](#appendix-1.-educational-opportunity-centers-eoc-issues-by-finding-sample-of-20)

[Appendix 2 Talent Search Issues by Finding (Sample of 20)
1](#appendix-2.-talent-search-issues-by-finding-sample-of-20)

[Appendix 3 EOC Grantees with Differences in Total Points Between the
Assessment Form and Funding Slate
1](#appendix-3.-eoc-grantees-with-differences-in-total-points-between-the-assessment-form-and-funding-slate)

[Appendix 4 EOC Grantees with Point Gains Due to Math and Transcription
Errors
1](#appendix-4.-eoc-grantees-with-point-gains-due-to-math-and-transcription-errors)

[Appendix 5 EOC Grantees with Point Losses Due to Math and Transcription
Errors
1](#appendix-5.-eoc-grantees-with-point-losses-due-to-math-and-transcription-errors)

[]{#__RefHeading___Toc207157165 .anchor}EXECUTIVE SUMMARY

The objective of our inspection was to evaluate the appropriateness of
the Office of Postsecondary Education's (OPE) awarding of prior
experience points in the 2006 Educational Opportunity Centers (EOC) and
Talent Search grant competitions. Our inspection is the result of a
request from Congress, dated October 2, 2007.

We found that OPE inappropriately awarded prior experience points for
the 2006 EOC and Talent Search grant competitions. As a result, some
grantees without prior experience near the funding threshold may have
been wrongly denied funding and some grantees above the funding
threshold may have been inappropriately awarded funding. Specifically,
we found that ---

1.  OPE's awarding of prior experience points was not in compliance with
    the regulations because OPE:

-   Improperly awarded partial points, and

-   Did not evaluate an objective in the Talent Search competition.

2.  OPE awarded points to grantees that did not meet minimum program
    requirements.

3.  OPE made errors in the execution of its prior experience points
    assessment.

-   In the EOC competition, OPE used incorrect source data, made
    documentation errors, and made math and transcription errors, and

-   In the Talent Search competition, OPE made documentation errors.

4.  OPE changed its process for awarding prior experience points without
    having the appropriate data to evaluate grantees.

-   In the EOC competition:

```{=html}
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```
-   Annual performance reports (APRs) lacked data for combined
    objectives,

-   OPE automatically awarded points due to lack of data, and

-   Grantee objectives did not correspond with the prior experience
    assessment.

```{=html}
<!-- -->
```
-   In the Talent Search competition:

```{=html}
<!-- -->
```
-   Grantee objectives did not correspond with the prior experience
    assessment.

We recommend that the Assistant Secretary for Postsecondary Education
---

-   Cease awarding partial prior experience points for Criterion 1 for
    future EOC and Talent Search grant competitions.

-   Develop a methodology for assessing prior experience for reentry in
    accordance with 34 C.F.R. § 643.22(b)(2) for future Talent Search
    grant competitions.

-   Cease awarding prior experience points to grantees for years that
    they do not meet minimum program requirements for future EOC and
    Talent Search grant competitions.

-   Develop a quality assurance process for the assessment of prior
    experience for future EOC competitions to ensure accountability and
    the accuracy of data and calculations.

-   Ensure that the data used to assess prior experience is clearly
    identified and sufficiently documented to support the calculation
    for future EOC and Talent Search grant competitions.

-   Ensure that the objectives used to assess prior experience
    correspond to grantees' application objectives for future EOC and
    Talent Search grant competitions.

We provided OPE with a copy of our draft report for comment. Based on
OPE's comments, we separated the first finding in the draft report into
two findings (Finding 1 and Finding 2), re-numbered the remaining
findings, and made various clarifications.

The recent reauthorization of the Federal TRIO programs by the Higher
Education Opportunity Act, Pub. L. 110-315 (enacted August 14, 2008),
specified changes to the criteria for evaluating prior experience that
may affect OPE's implementation of the recommendations made in this
report.

[]{#__RefHeading___Toc207157166 .anchor}BACKGROUND

On October 2, 2007, 15 members of Congress expressed concern that the
Department of Education (Department) inappropriately awarded prior
experience points in the 2006 Educational Opportunity Centers (EOC) and
Talent Search grant competitions and requested that we review this
matter.

The EOC and Talent Search programs are part of the Federal TRIO outreach
programs designed to support students from disadvantaged backgrounds.
These programs, implemented by the Department's Office of Postsecondary
Education (OPE), are targeted to serve and assist low-income,
first-generation college students and students with disabilities. Both
the EOC and Talent Search programs serve low-income, first generation
college students. The EOC program provides counseling and information on
college admissions to qualified adults who want to enter or continue a
program of postsecondary education. The Talent Search program provides
academic, career, and financial counseling to its participants from
disadvantaged backgrounds and encourages them to graduate from high
school and continue on to a postsecondary institution. The regulations
at 34 C.F.R. § 644.32(b) specify that an EOC grantee shall serve a
minimum of 1,000 participants in each year, while the regulations at 34
C.F.R. § 643.32(b) specify that a Talent Search grantee shall serve a
minimum of 600 participants in each year.

The EOC and Talent Search programs hold grant competitions every four
years. The Secretary evaluates an application for a new grant based on
the project's need, objectives, plan of operation, applicant and
community support, quality of personnel, budget, and evaluation plan.
The maximum application score for these criteria is 100 points.

The Secretary also awards a maximum of 15 additional points for prior
grant experience. Unlike the application scores determined by
individuals serving as field readers who are external to the Department,
prior experience points are determined by Department staff. The Higher
Education Act of 1965, as amended (HEA), specifies that the Department
should remain historically consistent in its application of prior
experience points for future competitions by not varying from the level
of consideration provided to grant applicants during fiscal years 1994
through 1997. The number of points awarded for prior experience has
remained consistent since the specified period of time. Although OPE
modified its formula for evaluating prior experience for both the EOC
and Talent Search competitions in 2006, it did not change the maximum
number of points grantees were eligible to earn.

For the 2006 competitions, OPE assessed grantees for their prior
experience in fiscal years 2002-03, 2003-04, and 2004-05. The
regulations at 34 C.F.R. § 644.22(b) for the EOC program and 34 C.F.R. §
643.22(b) for the Talent Search program specify that the Secretary
evaluate prior experience based on three sets of criteria. Criterion 1
for both programs, with a maximum score of three points, requires that
the Secretary evaluate whether the applicant provided services to the
number of participants required to be served and whether two-thirds of
all participants served were low-income individuals and potential
first-generation college students.

Criteria 2 and 3 for both programs require the Secretary to evaluate
specific subsets of the population served by the applicant. Each
criterion is worth a maximum of six points. Under Criterion 2 for the
EOC program, the Secretary evaluates the extent to which the applicant
met or exceeded its objectives regarding the provision of assistance to
individuals in applying for admission to, or financial aid for, programs
of postsecondary education. Under Criterion 3, the Secretary evaluates
the extent to which the applicant met or exceeded its objectives
regarding the admission or reentry of participants to programs of
postsecondary education. Under Criterion 2 for the Talent Search
program, the Secretary evaluates the extent to which the applicant met
or exceeded its objectives regarding the retention, reentry, and
graduation levels of secondary school participants, while under
Criterion 3, the Secretary evaluates the extent to which the applicant
met or exceeded its objectives regarding the admission or reentry of
participants to programs of postsecondary education.

OPE had 335 grant applicants for the 2006 EOC competition and funded
125. All funded applicants were eligible for and received prior
experience points. There were a total of 137 EOC grantees that were
assessed for prior experience. The funding threshold for the 2006 EOC
competition was 100.33 points out of a maximum of 115 points.

OPE had 772 grant applicants in the 2006 Talent Search competition and
funded 468. Of these, 400 were eligible for and received prior
experience points, and one was eligible but did not earn any points.
There were 457 Talent Search grantees that were assessed for prior
experience and eligible for funding. The threshold for the 2006 Talent
Search competition was 98.33 points out of a total of 115 points.

The recent reauthorization of the Federal TRIO programs by the Higher
Education Opportunity Act, Pub. L. 110-315 (enacted August 14, 2008),
specified changes to the criteria for evaluating prior experience that
may affect OPE's methodology for awarding prior experience points.

[]{#__RefHeading___Toc207157167 .anchor}INSPECTION RESULTS

The objective of our inspection was to evaluate the appropriateness of
OPE's awarding of prior experience points in the 2006 EOC and Talent
Search grant competitions. We found that OPE inappropriately awarded
prior experience points for the 2006 EOC and Talent Search grant
competitions. As a result, some grantees without prior experience near
the funding threshold may have been wrongly denied funding and some
grantees above the funding threshold may have been inappropriately
awarded funding.

We found that (1) OPE's awarding of prior experience points was not in
compliance with the regulations, (2) OPE awarded points to grantees that
did not meet minimum program requirements, (3) OPE made errors in the
execution of its prior experience points assessment, and (4) OPE changed
its process for awarding prior experience points without having the
appropriate data to evaluate grantees.

[]{#__RefHeading___Toc207157168 .anchor}FINDING NO. 1 -- OPE's Awarding
of Prior Experience Points was Not in Compliance with the Regulations

We found that OPE improperly awarded partial points in both the EOC and
Talent Search competitions. In our sample of 20 EOC grantees, we found
that OPE did not award prior experience points in compliance with the
regulations for 4 of the grantees (see Appendix 1). We also found that
OPE did not evaluate an objective in the Talent Search competition. In
our sample of 20 Talent Search grantees, we found that OPE did not award
prior experience points in compliance with the regulations for 16 of the
grantees (see Appendix 2).

## OPE Improperly Awarded Partial Points {#ope-improperly-awarded-partial-points .RptSubcaption}

The EOC regulations at 34 C.F.R. § 644.22(b)(1) state that the Secretary
should evaluate prior experience for Criterion 1 based on the following:

> \(i\) Whether the applicant provided services to the required number
> of participants who resided in the target area; *and* (ii) Whether
> two-thirds of all participants served were low-income individuals and
> potential first-generation college students \[emphasis added\].

OPE evaluated Criterion 1 in two parts for the EOC competition. The
regulations at 34 C.F.R.

§ 644.22(b)(1)(i) correspond to Criterion 1a of the EOC assessment, and
the regulations at 34 C.F.R. § 644.22(b)(1)(ii) correspond to Criterion
1b.

The Talent Search regulations at 34 C.F.R. § 643.22(b)(1) similarly
state that the Secretary should evaluate prior experience for Criterion
1 based on the following:

> \(i\) Whether the applicant provided services to the number of
> participants required to be served under the approved application;
> *and* (ii) Whether two-thirds of all participants served were
> low-income individuals and potential first-generation college students
> \[emphasis added\].

Like the EOC competition, OPE evaluated Criterion 1 in two parts for the
Talent Search competition. The regulations at 34 C.F.R. §
643.22(b)(1)(i) correspond to Criterion 1a of the Talent Search
assessment. The regulations at 34 C.F.R. § 643.22(b)(1)(ii) correspond
to Criterion 1b.

OPE awarded partial points for Criterion 1 in both the EOC and Talent
Search competitions. A grantee could earn a maximum of 1.5 points for
meeting Criterion 1a, and another 1.5 points for meeting Criterion 1b.
The regulations, however, state that an applicant should be awarded
three points for meeting both part (i) *and* part (ii).

In the 2002 EOC and Talent Search competitions, when a grantee did not
serve the number of participants it was funded to serve (funded to serve
number), OPE used two-thirds of the actual number of participants served
for Criterion 1b. This method rewarded some grantees with prior
experience points although they did not meet the terms of their grant
agreements. For the 2006 EOC and Talent Search competitions OPE used the
larger of the actual number served or the funded to serve number to
calculate Criterion 1b.[^1] This new method made it more difficult for
grantees to earn prior experience points in 2006 by appropriately
requiring grantees to serve the required minimum number of low-income
and potential first-generation college students in order to receive
points under Criterion 1b; however, the method still allowed some
grantees to receive prior experience points without meeting the terms of
their grant agreement identified in Criterion 1a. Of the 20 EOC grantees
in our sample, 4 received partial points for Criterion 1. Of the 20
Talent Search grantees in our sample, 7 received partial points.

Like the 2002 competitions, OPE continued to award partial points to
grantees for Criterion 1. OPE did not correctly interpret the inclusive
nature of the "and" in the regulations for Criterion 1 for both the EOC
and Talent Search programs. OPE's practice of awarding partial points
has not considered the requirement in the regulations that both
conditions, parts (i) and (ii), must be met to earn prior experience
points. Grantees that earned partial points had an advantage over new
applicants that did not have prior experience. As the regulation is
written, a grantee should not be able to earn prior experience points
for Criterion 1 without meeting the requirements of both Criterion 1a
and Criterion 1b.

## OPE Did Not Evaluate Reentry in the Talent Search Competition {#ope-did-not-evaluate-reentry-in-the-talent-search-competition .RptSubcaption}

The Talent Search regulations at 34 C.F.R. § 643.22(b)(2) state that the
Secretary should evaluate prior experience for Criterion 2 based on
"\[t\]he extent to which the applicant met or exceeded its objectives
regarding the retention, reentry, and graduation levels of secondary
school participants." In the 2006 Talent Search competition, OPE
evaluated prior experience only for retention and graduation, even
though the regulations provide that all three objectives should be
evaluated. An OPE official stated that reentry was not evaluated because
not every grantee had a reentry objective. There were applicants in the
competition, however, that had reentry objectives stated in their
applications. Of the 20 Talent Search grantees in our sample, 12 had a
reentry objective percentage for Criterion 2. Because OPE did not
evaluate reentry, grantees with reentry objectives were not properly
evaluated for this criterion and may not have received the correct
number of prior experience points.

## Recommendations {#recommendations .RptSubcaption}

We recommend that the Assistant Secretary for Postsecondary Education
---

1.  Cease awarding partial prior experience points for Criterion 1 for
    future EOC and Talent Search grant competitions.

2.  Develop a methodology for assessing prior experience for reentry in
    accordance with 34 C.F.R. § 643.22(b)(2) for future Talent Search
    grant competitions.

[]{#__RefHeading___Toc207157169 .anchor}FINDING NO. 2 -- OPE Awarded
Points to Grantees that Did Not Meet Minimum Program Requirements

In both the EOC and Talent Search grant competitions, OPE awarded prior
experience points to grantees that did not comply with the minimum
program requirements. The EOC program requires grantees to serve a
minimum of 1,000 participants, while the Talent Search program requires
a minimum of 600 participants. Grantees that failed to serve the minimum
number of program participants did not comply with the basic
requirements of the grant and should not be awarded prior experience
points for any of the criteria in those years. Therefore, OPE provided
these grantees with an advantage by awarding points for years where they
did not meet minimum requirements. Of the 20 EOC grantees in our sample,
5 received prior experience points in years where they did not meet the
minimum requirement. Of the 20 Talent Search grantees in our sample, 2
received such points in years where they did not meet the minimum
requirement.[^2]

## Recommendation {#recommendation .RptSubcaption}

We recommend that the Assistant Secretary for Postsecondary Education
---

1.  Cease awarding prior experience points to grantees for years that
    they do not meet minimum program requirements for future EOC and
    Talent Search grant competitions.

[]{#__RefHeading___Toc207157170 .anchor}FINDING NO. 3 -- OPE Made Errors
in the Execution of its Prior Experience Points Assessment

We found that OPE made execution errors in assessing prior experience
for the EOC and Talent Search competitions. In our sample of 20 EOC
grantees, we found that OPE made execution errors in assessing prior
experience for 16 of the grantees (see Appendix 1). In our sample of 20
Talent Search grantees, we found that OPE made execution errors in
assessing prior experience for 7 of the grantees (see Appendix 2).

## OPE Made Execution Errors in Assessing Prior Experience for the EOC Competition {#ope-made-execution-errors-in-assessing-prior-experience-for-the-eoc-competition .RptSubcaption}

In the EOC competition, OPE program specialists manually performed the
assessment calculations. The prior experience assessments for the EOC
competition contained incorrect source data, lacked documentation, and
had math and transcription errors.

***Incorrect source data.*** The prior experience assessment forms in
the EOC competition contained incorrect data obtained from the
applications, the annual performance reports (APRs), and a spreadsheet
containing data for Criterion 1.[^3] Errors included program specialists
transcribing a number incorrectly from the source document to the
assessment form and using the wrong data element from the source
document to evaluate a criterion on the assessment form. These errors
resulted in inaccurate assessments of prior experience because incorrect
numbers were used in the calculations. OPE did not have an adequate
quality assurance process in place to check for these errors. Of the 20
EOC grantees in our sample, 12 had source data errors.

***Lack of documentation.*** The prior experience assessment forms in
the EOC competition lacked sufficient documentation. Of the 137 EOC
prior experience assessments, we found that 34 assessments (25%) had
insufficient documentation of the scoring on the assessment form to
determine whether the criteria were appropriately evaluated. Program
specialists' documentation errors on the assessment form included
determining achievement rates but not providing all of the information
necessary to perform the calculation and not including the objective
percentages from the application. Without adequate documentation of the
assessment scoring, there is no assurance that the data used to evaluate
prior experience is accurate and appropriate.

In addition to the issues we identified on the assessment forms, there
was also a lack of documentation for changes from the total prior
experience points stated on the assessment form to the total points
stated on OPE's slate used for funding grantees. We found that for 12 of
the 137 EOC prior experience assessments (9%), the grantee's total prior
experience points on the assessment form did not match the total points
on the slate (see Appendix 3). A program official stated that the
Director of TRIO at the time randomly selected grantees to review and
based on the review personally made changes to some scores. Without
documentation, however, we were unable to determine whether these
differences were the result of a deliberate change and, if so, whether
the change was justified; or whether there was a transcription error.

Six of the 20 grantees in our sample had discrepancies between the
funded to serve number requested in the application and the number
contained in the spreadsheet provided to program specialists for
evaluating Criterion 1. For four discrepancies, OPE used an incorrect
number to assess prior experience. The grantee files did not contain
documentation explaining the discrepancy. OPE officials stated that for
some discrepancies between the funded to serve number requested in the
application and the number used to evaluate prior experience, it was
common practice to reduce the funded to serve number from the
application to the funded to serve number from the prior grant cycle if
the grantee did not receive the additional funds it requested in its
application. OPE explained that the other two discrepancies resulted
from this practice. The grantee files did not contain written approval
to document and justify the change to the number funded to serve.
Without written justification, there is no assurance that the funded to
serve number used to evaluate prior experience was accurate.

***Math and transcription errors.*** Of the 137 EOC prior experience
assessments, 76 (55%) contained mathematical errors. Thirty-eight had
errors that resulted in OPE inappropriately awarding prior experience
points. Of these, 17 grantees gained points that they had not earned and
21 grantees lost points that they had earned (see Appendices 4 and 5).
Some grantees had significant changes in points. For example, four
grantees gained three or more points due to errors, while nine grantees
lost three or more points.

Program specialists' math and transcription errors included:

-   Making calculation errors such as addition, multiplication, and
    division errors,

-   Determining the correct achievement rate but awarding the wrong
    number of points,

-   Reversing the numerator and the denominator in a calculation,

-   Transcribing the wrong number from the calculation sheets to the
    cover sheet, and

-   Incorrectly totaling the points on the cover sheet.

Execution errors in the assessment of prior experience were caused by
inadequate internal controls. The EOC prior experience assessment lacked
an adequate quality assurance process. OPE officials stated that there
was no comprehensive review of the program specialists' work on the
prior experience assessment forms. The control activities discussed in
the Government Accountability Office (GAO) *Standards for Internal
Control in the Federal Government* specify that there should be controls
over information processing, which include activities such as edit
checks of data entered. OPE did not have any controls in place to ensure
data integrity.

In addition, many program specialists did not sign and date their
completed assessment forms. Failure to ensure completion of this
certification requirement indicates a control environment that lacks
accountability.

## OPE Made Execution Errors in Assessing Prior Experience for the Talent Search Competition {#ope-made-execution-errors-in-assessing-prior-experience-for-the-talent-search-competition .RptSubcaption}

***Lack of documentation.*** OPE used an automated spreadsheet to
calculate prior experience points for the Talent Search competition.
There were discrepancies between the funded to serve number requested in
the application and the number used in the spreadsheet for 7 of the 20
grantees in our sample. For one discrepancy, OPE used an incorrect
number to assess prior experience. The grantee file did not contain
documentation explaining this discrepancy. For another discrepancy, OPE
stated that it used the funded to serve number from the previous grant
cycle because the grantee reduced the funded to serve number requested
in its application without prior approval. As noted above, OPE officials
stated that in some other cases it was common practice to reduce the
funded to serve number from the application to the funded to serve
number used in the prior grant cycle if the grantee did not receive the
additional funds it requested in its application. OPE explained that the
other five discrepancies resulted from this practice. The grantee files
did not contain written approval to document and justify the change to
the number funded to serve. As stated earlier, without written
justification, there is no assurance that the number funded to serve
used to evaluate prior experience was accurate.

## Recommendations {#recommendations-1 .RptSubcaption}

We recommend that the Assistant Secretary for Postsecondary Education
---

1.  Develop a quality assurance process for the assessment of prior
    experience for future EOC competitions to ensure accountability and
    the accuracy of data and calculations.

2.  Ensure that the data used to assess prior experience is clearly
    identified and sufficiently documented to support the calculation
    for future EOC and Talent Search grant competitions.

[]{#__RefHeading___Toc207157171 .anchor}FINDING NO. 4 -- OPE Changed its
Process for Awarding Prior Experience Points without Having the
Appropriate Data to Evaluate Grantees

OPE modified the methodology for awarding prior experience points for
the 2006 EOC and Talent Search grant competitions. In making this
change, however, OPE failed to take into account the limitations of the
data it collected from grantees and did not have the data needed to
support the modified methodology. In our sample of 20 EOC grantees, we
found that 5 had an issue that resulted from OPE changing its process
for awarding prior experience points without having the appropriate data
to evaluate grantees (see Appendix 1). In our sample of 20 Talent Search
grantees, we found that 8 had an issue (see Appendix 2).

## OPE Changed its Process without Having the Appropriate Data in the EOC Competition {#ope-changed-its-process-without-having-the-appropriate-data-in-the-eoc-competition .RptSubcaption}

Under Criterion 2 for the EOC program, the Secretary evaluates the
extent to which the applicant met or exceeded its objectives regarding
the provision of assistance to individuals in applying for admission to,
or financial aid for, programs of postsecondary education. For this
criterion, OPE provided program specialists with different methods to
calculate prior experience for 2002-03 and 2003-04. A grantee could be
awarded prior experience points for each individual objective of
assisting participants with applying for postsecondary admissions and
for financial aid or the objectives could be combined into one objective
to award the points.

Under Criterion 3, the Secretary evaluates the extent to which the
applicant met or exceeded its objectives regarding the admission or
reentry of participants to programs of postsecondary education. For this
criterion, OPE also provided program specialists with different methods
to calculate prior experience for 2002-03 and 2003-04. A grantee could
be awarded prior experience points for each individual objective of
enrollment in postsecondary education and reentry to postsecondary
education; enrollment only in postsecondary education; or the objectives
for enrollment in postsecondary education and reentry to postsecondary
education could be combined into one objective.

***Annual Performance Reports (APRs) Lacked Data for Combined
Objectives.*** To determine the number of students a grantee assisted
under both criteria, program specialists were instructed to take the
corresponding number of participants assisted for each objective from
the APR. Because the APR did not have a specific field for grantees to
report on combined objectives, OPE instructed program specialists to add
the numbers for each objective to determine the combined number assisted
under each criterion. Since an individual could receive assistance under
both objectives for each criterion, these numbers could overlap, leading
to double counting. The numerator for the combined objective was not
adjusted to account for the double counting, resulting in 40 of the 137
EOC grantees (29%) evaluated for prior experience having an achievement
rate greater than 100 percent. Program specialists had flexibility in
determining whether an objective should be evaluated as separate or
combined. In cases where a program specialist used a combined objective,
grantees had the benefit of double counting, making it easier to earn
prior experience points.

***OPE Automatically Awarded Points Due to Lack of Data.*** OPE decided
to automatically award prior experience points to all EOC applicants
with prior grant experience for Criteria 2 and 3 for 2004-05. OPE
automatically awarded all grantees with prior experience 4 of the 15
prior experience points, giving them an advantage over applicants
without any prior experience. OPE awarded these points without
evaluating whether the grantee had achieved the two criteria for that
year. OPE made this decision because it did not request one of the data
elements in the 2004-05 APR that was necessary to determine whether the
grantee had earned prior experience points for these two criteria. An
OPE official stated that OPE eliminated the data element from the APR
because grantees had different interpretations of the data element and
the data collected was considered unreliable. Although OPE did not
consider the data reliable and eliminated the data element from the APR
for 2004-05, OPE used it to calculate prior experience points for
2002-03 and 2003-04.

For the 2006 competition, all of the grant applicants that were funded
were prior grantees who earned prior experience points. The funding
threshold in 2006 was 100.33 points. There were 19 grantees that were
not eligible for prior experience points, but had perfect application
scores of 100. These grantees with perfect application scores may have
received funding had OPE not automatically awarded points because
grantees with prior experience may have fallen below the funding
threshold.

***Grantee Objectives Did Not Correspond with the Prior Experience
Assessment.*** Though OPE modified the methodology for calculating prior
experience points in 2006, the grantees' original application objectives
were written for the 2002 competition and did not necessarily correspond
with the new methodology. In some cases where the grantees' objectives
did not correspond with the prior experience assessment, program
specialists would give grantees the benefit of the doubt by looking for
similar objectives or using key words to find other objectives to use in
the prior experience assessment. In other cases, program specialists
would use objective percentages from the APR that were not stated in the
grantees' original approved applications. Without precise data and
standardized objectives, there is no assurance that grantees were
appropriately evaluated for the objectives stated in their applications.
In our random sample of 20 EOC grantees, 2 grantees had objectives in
their applications that did not correspond with the objectives used to
evaluate prior experience.

## OPE Changed its Process without Having the Appropriate Data in the Talent Search Competition {#ope-changed-its-process-without-having-the-appropriate-data-in-the-talent-search-competition .RptSubcaption}

Under Criterion 2 for the Talent Search program, the Secretary evaluates
the extent to which the applicant met or exceeded its objectives
regarding the retention, reentry, and graduation levels of secondary
school participants, while under Criterion 3, the Secretary evaluates
the extent to which the applicant met or exceeded its objectives
regarding the admission or reentry of participants to programs of
postsecondary education.

***Grantee Objectives Did Not Correspond with the Prior Experience
Assessment.*** In our sample of 20 Talent Search grantees, 5 provided
more than one percentage for a single objective in the application. In
these cases, the number chosen for the prior experience assessment
depended on the program specialist performing the calculation. In some
cases program specialists would average the numbers, while in other
instances they would just select one of the numbers. Four Talent Search
grantees in our sample of 20 had application objectives that did not
correspond with the modified methodology for calculating prior
experience points in 2006. As noted above, in some cases program
specialists would give grantees the benefit of the doubt when the
grantees' objectives did not correspond with the prior experience
assessment. Therefore, there is no assurance that grantees were
appropriately evaluated for the objectives stated in their application.

**Changes to the Grant Applications for the EOC and Talent Search Grant
Competitions**

OPE has taken steps to address issues we identified in the 2006 EOC and
Talent Search grant competitions. The prior experience assessments for
the next grant competitions will use data from the 2006 EOC and Talent
Search grant applications. Unlike the 2002 grant competitions, in 2006
OPE required all applicants to use specific, standardized objectives
stated in the application form. An OPE official stated that these
standardized objectives will be used to evaluate prior experience in
future EOC and Talent Search competitions. Using these standardized
objectives should reduce variations in grantees' objectives and
eliminate problems associated with evaluating combined objectives. In
addition, OPE revised the 2006 EOC grant application form to define the
data elements used in the standardized objectives.

## Recommendation {#recommendation-1 .RptSubcaption}

We recommend that the Assistant Secretary for Postsecondary Education
---

1.  Ensure that the objectives used to assess prior experience
    correspond to grantees' application objectives for future EOC and
    Talent Search grant competitions.

[]{#__RefHeading___Toc207157172 .anchor}DEPARTMENT COMMENTS

On June 5, 2008, we provided OPE with a copy of our draft report for
comment. OPE provided its comments to the report on July 11, 2008. Based
on OPE's comments, we separated the first finding in the draft report
into two findings: Finding 1 and Finding 2. As a result, we renumbered
Finding 2, Finding 3, and their corresponding recommendations. OPE did
not agree with Finding 1 of the draft report and agreed with Findings 2
and 3. A copy of OPE's comments, in their entirety, is attached to this
report.

The recent reauthorization of the Federal TRIO programs by the Higher
Education Opportunity Act, Pub. L. 110-315 (enacted August 14, 2008),
specified changes to the criteria for evaluating prior experience that
may affect OPE's implementation of the recommendations made in this
report.

**[Finding 1]{.underline}**

OPE did not agree with Finding 1 or with Recommendations 1.1, 1.2 (now
2.1), and 1.3 (now 1.2). OPE stated the draft report did not provide any
significant legal or policy rationale for the interpretation of the
regulations.

**Recommendation 1.1**

Cease awarding partial prior experience points for Criterion 1 for
future EOC and Talent Search grant competitions.

***OPE Comments***

OPE did not agree with our recommendation. OPE stated that the OIG's
interpretation of the Department's regulations was that an applicant can
receive only the specific number of prior experience points for each
criterion or zero. OPE stated that the Department has interpreted its
regulations as providing a maximum number of points for each criterion.

***OIG Response***

No changes have been made to the finding and recommendation based on
OPE's comments to Recommendation 1.1; however, we clarified the
discussion of OPE's scoring of Criterion 1b in the 2006 competitions.

We recognize that the Department has the discretion to interpret its
regulations, and is entitled to deference if the interpretation is
reasonable. Our finding describes in detail our conclusion that the
plain text of the regulation and the use of "and" to link the two parts
of Criterion 1 requires that both parts of the provision be satisfied to
earn any of the three available points under Criterion 1. OPE did not
provide any explanation as to why its interpretation and application
were considered reasonable in light of the plain text of the regulation.
The EOC and Talent Search programs are targeted to serve and assist
low-income, first-generation college students. OPE funds EOC and Talent
Search grant applicants based on the number of participants the grantees
will serve. In their applications, grantees agree that two-thirds of
those participants will be low-income, first-generation college
students. OPE's methodology of awarding points allows grantees to
receive points without meeting the terms of their grant agreement. For
example, in one case a grantee served the number of participants it was
funded to serve, but only four percent of those students were
low-income, first-generation college students. OPE awarded points for
Criterion 1 although the grantee had not served the targeted students.
Points should be awarded to fully support and reinforce program
objectives.

**Recommendation 1.2**

Cease awarding prior experience points to grantees for years that they
do not meet minimum program requirements for future EOC and Talent
Search grant competitions.

***OPE Comments***

OPE did not agree with our recommendation. OPE stated that the prior
experience sections of the regulations do not cite the minimum number of
participants. OPE stated that the Department has concluded that it would
not be appropriate to deny all prior experience points to a grantee who
may have been just short of the minimum number of participants. As noted
above, OPE stated that the draft report did not provide a legal or
policy rationale for the interpretation of the regulations.

***OIG Response***

No changes have been made to the recommendation. We agree in part with
OPE's statement that the prior experience sections of the regulations do
not specifically reference the required minimum number of program
participants. For the EOC and Talent Search programs, Criteria 2 and 3
(34 C.F.R. § 644.22(b)(2) & (3) and 34 C.F.R. § 643.22(b)(2) & (3),
respectively) are not explicitly linked to a grantee serving the minimum
number of participants; however, eligibility for prior experience points
under Criterion 1 for both programs is conditioned on the grantee
serving the minimum number of program participants. The regulations at
34 C.F.R. § 644.32 require that an EOC grantee serve a minimum of 1,000
participants, and the regulations at 34 C.F.R. § 643.32 require that a
Talent Search grantee serve a minimum of 600 participants.[^4] If a
grantee has not served the minimum number of participants specified in
the regulations, then the grantee has not met the requirements of the
program. In cases where a grantee does not comply with grant
requirements, the Department's *Handbook for the Discretionary Grant*
*Process* states that program staff can initiate action to suspend or
terminate the grant. Therefore, awarding prior experience points for
years where the fundamental program requirements were not met undermines
the integrity of the minimum program requirements.

As a result of OPE's policy of awarding of prior experience points,
program funds may not be targeted in the most effective way at the
intended program beneficiaries. OPE's policy of awarding prior
experience points to grantees that have failed to meet minimum program
requirements inappropriately provides these grantees with an advantage.
This policy may exclude worthy new grant applicants with the ability to
serve the disadvantaged student population targeted by the program
statute from receiving a grant. OPE stated that it would not be
appropriate to deny all prior experience points to a grantee who may
have been just short of the minimum number of participants; however, OPE
awarded points to grantees in years where they served far below the
minimum number. For example, in the 2006 Talent Search competition, 12
grantees were funded at the minimum program requirement but failed to
meet this requirement by more than 50 participants. These grantees still
received prior experience points for that year.

If OPE believes that the minimum program requirement is not achieving
the intended program results, OPE should amend the regulations to better
align its current activities with the EOC and Talent Search program
objectives.

**Recommendation 1.3**

Develop a methodology for assessing prior experience for reentry in
accordance with 34 C.F.R.

§ 643.22(b)(2) for future Talent Search grant competitions.

***OPE Comments***

OPE did not agree with our recommendation. OPE stated that the
recommendation misstated the conclusion of the draft report. OPE stated
that the draft report does not say that OPE did not have a methodology
for assessing prior experience for reentry, but noted that the
Department did not consider reentry as a criterion during the 2006
Talent Search competition. OPE stated that it did have a methodology for
assessing prior experience for reentry by determining that it was more
appropriate to consider awarding prior experience points only when the
prior experience related to a shared goal of all grantees and when all
grantees could be considered on an equal basis.

***OIG Response***

No changes have been made to the finding and recommendation based on
OPE's comments to Recommendation 1.3. We disagree with OPE's statement
that our recommendation misstated the conclusion of the draft report. As
stated in our report, OPE did not evaluate reentry in its assessment of
prior experience. The regulations at 34 C.F.R. § 643.22(b)(2) state that
the Department must evaluate "\[t\]he extent to which the applicant met
or exceeded its objectives regarding the retention, reentry, and
graduation levels of secondary school participants." Our recommendation
is that OPE develop a methodology for assessing prior experience for
reentry in accordance with 34 C.F.R. § 643.22(b)(2) for future Talent
Search grant competitions.

OPE stated that it was more appropriate to award prior experience points
when all grantees had a shared goal and could be considered on an equal
basis; however, the regulations require that OPE evaluate reentry when
the applicant had the objective in its application. As stated in our
report, OPE did not evaluate reentry even for applicants that had
reentry objectives in their applications.

**[Finding 2 (now Finding 3)]{.underline}**

**Recommendation 2.1**

Develop a quality assurance process for the assessment of prior
experience for future EOC competitions to ensure accountability and the
accuracy of data and calculations.

***OPE Comments***

OPE agreed with Finding 2 in the draft report, but noted that it
implemented several quality assurance measures to ensure accountability
and the accuracy of data calculations for the Upward Bound and Ronald E.
McNair Postbaccalaureate Achievement (McNair) prior experience
assessment processes.

***OIG Response***

No changes have been made to the finding and recommendation. Although
OPE has implemented measures that may improve the quality assurance
process for the Upward Bound and McNair Programs, OPE should also
develop a quality assurance process specifically for the assessment of
prior experience in future EOC competitions.

**Recommendation 2.2**

Ensure that the data used to assess prior experience is clearly
identified and sufficiently documented to support the calculation for
future EOC and Talent Search grant competitions.

***OPE Comments***

OPE noted that it developed extensive instructions to provide guidance
and policies for assessing prior experience for the Upward Bound and
McNair programs. OPE also stated that it used a "buddy system" to
promote quality assurance and provided extensive training on prior
experience assessment to staff.

***OIG Response***

No changes have been made to the finding and recommendation. OPE may
have improved quality assurance and provided guidance to program
specialists on how to identify and document support for prior experience
calculations in the Upward Bound and McNair Programs; however, OPE
should also implement measures in the EOC and Talent Search competitions
to ensure that the data used to assess prior experience is clearly
identified and sufficiently documented.

**[Finding 3 (now Finding 4)]{.underline}**

**Recommendation 3.1**

Ensure that the objectives used to assess prior experience correspond to
grantees' application objectives for future EOC and Talent Search grant
competitions.

***OPE Comments***

OPE agreed with Finding 3 in the draft report, but noted that it
implemented the following improvements to address this recommendation:
(1) established standard mandatory objectives for all Talent Search and
EOC applicants, (2) required grantees to establish the number of
participants to be served each year and the targets for each of the
standard objectives that will be used to assess prior experience points,
(3) revised the APR for the new grant cycle to conform to the data
reporting requirements of the new standard objectives, and (4)
pre-populated the approved objectives into the 2006-07 APR.

***OIG Response***

No changes have been made to the finding and recommendation. Although
OPE may have established standard mandatory objectives and revised the
APR, OPE should ensure that the objectives used to assess prior
experience correspond to the mandatory objectives in the grantees'
application.

[]{#__RefHeading___Toc207157173 .anchor}OBJECTIVE, SCOPE, AND
METHODOLOGY

The objective of our inspection was to evaluate the appropriateness of
the Office of Postsecondary Education's (OPE) awarding of prior
experience points in the 2006 Educational Opportunity Centers (EOC) and
Talent Search grant competitions.

We began our fieldwork on November 30, 2007, and conducted an exit
conference on May 14, 2008.

We reviewed applicable laws and regulations related to determining prior
experience for the EOC and Talent Search programs and interviewed
Department staff in OPE and OGC. We also reviewed the following
documentation provided by OPE:

-   EOC APRs for 2002-03 and 2003-04

-   Talent Search APRs for 2002-03, 2003-04, and 2004-05

-   2006 EOC and Talent Search Slates

-   EOC Prior Experience Assessment Forms

-   EOC Spreadsheet for Criterion 1

-   Talent Search Prior Experience Calculation Spreadsheet

To answer our objective, we selected a random sample of 20 grant
applicants from a total of 137 EOC prior grantees that were assessed for
prior experience in the 2006 grant competition. We also selected a
random sample of 20 grant applicants from a total of 457 Talent Search
prior grantees that were eligible for funding and assessed for prior
experience in the 2006 grant competition.

To determine if OPE used the appropriate information to assess prior
experience for EOC, we compared the information in the EOC prior
experience assessment forms to the grant applications, the APRs, and the
EOC spreadsheet for Criterion 1 for the 20 grantees in our sample. We
replaced two of the grantees in our original EOC sample because OPE was
unable to locate all of the documentation for these grantees at the time
of our review. We did not report the missing files as an issue because
OPE subsequently informed us that they were able to locate the files.

To determine if OPE used the appropriate information to assess prior
experience for Talent Search, we compared the information in the Talent
Search prior experience calculation spreadsheet to the grant
applications and the APRs for the 20 grantees in our sample.

To determine if OPE appropriately calculated prior experience points, we
verified the calculations on all 137 EOC prior experience assessment
forms and evaluated the formula used in the Talent Search PE calculation
spreadsheet.

To verify the accuracy of the total prior experience scores stated in
the 2006 EOC and Talent Search slates, we compared the total prior
experience scores in the slates to the total prior experience scores on
the 137 EOC prior experience assessment forms and for the 457 Talent
Search grantees in the prior experience calculation spreadsheet.

Our inspection was performed in accordance with the *2005 President's
Council on Integrity and Efficiency Quality Standards for Inspections*
appropriate to the scope of the inspection described above.

[]{#__RefHeading___Toc207157174 .anchor}APPENDICES

## Appendix 1. Educational Opportunity Centers (EOC) Issues by Finding (Sample of 20) {#appendix-1.-educational-opportunity-centers-eoc-issues-by-finding-sample-of-20 .Closing}

  --------------- ---------------------------------- ------------- ------- -------- -------
                                                     **Finding**                    

  **Application   **Grantee**                        **1**         **2**   **3**    **4**
  No.**                                                                             

  P066A060140     College Board                                            X        

  P066A060329     Connecticut Talent Assistance                            X        
                  Cooperative                                                       

  P066A060309     Montgomery College                               X       X        

  P066A060069     East Central University                                  X        

  P066A060146     Southeastern Louisiana University                                 

  P066A060230     South Carolina State University                                   X

  P066A060135     Ohio Appalachian Center for Higher X                     X        
                  Ed.                                                               

  P066A060224     Victoria County Junior College                   X       X        
                  District                                                          

  P066A060030     Inter American University of                                      X
                  Puerto Rico                                                       

  P066A060201     Southwest Tennessee Community      X             X       X        
                  College                                                           

  P066A060270     University of Maine                                      X        

  P066A060145     University of Cincinnati                                 X        

  P066A060193     Mount Wachusett Community College  X             X                

  P066A060039     Inter American University of                             X        
                  Puerto Rico/ Arecibo                                              

  P066A060068     Lake Michigan College              X                     X        

  P066A060134     Inter American University of                             X        
                  Puerto Rico                                                       

  P066A060158     University of Wyoming                                    X        

  P066A060113     University of Georgia                                    X        X

  P066A060281     Atlanta Metropolitan College                     X       X        X

  P066A060303     Piedmont Community College                               X        X

                  **Total:**                         **4**         **5**   **16**   **5**
  --------------- ---------------------------------- ------------- ------- -------- -------

**Finding 1** OPE's awarding of prior experience points was not in
compliance with the regulations.

**Issue:** 1. OPE improperly awarded partial points.

**Finding 2** OPE awarded points to grantees that did not meet minimum
program requirements.

**Issue:** 1. OPE awarded points to grantees that did not meet minimum
program requirements.

**Finding 3** OPE made errors in the execution of its prior experience
points assessment.

**Issues:** 1. OPE used incorrect source data.

2\. OPE made documentation errors.

3\. OPE made math and transcription errors.

**Finding 4** OPE changed its process for awarding prior experience
points without having the appropriate data to evaluate grantees.

**Issues:** 1. Double counting of number assisted resulted in an
achievement rate greater than 100%.

2\. Grantee objectives did not correspond with the prior experience
assessment.

## Appendix 2. Talent Search Issues by Finding (Sample of 20) {#appendix-2.-talent-search-issues-by-finding-sample-of-20 .Closing}

  --------------- ---------------------------------- ------------- ------- ------- -------
                                                     **Finding**                   

  **Application   **Grantee**                        **1**         **2**   **3**   **4**
  No.**                                                                            

  P044A060076     New Mexico Junior College          X                     X       X

  P044A060191     National League of Cuban American                        X       X
                  Community Based Centers                                          

  P044A060027     Robert Morris College              X                     X       X

  P044A060580     Douglas Cherokee Economic          X                             
                  Authority, Inc.                                                  

  P044A060137     SUNY/Potsdam                       X                     X       

  P044A060073     Tuskegee University                                              

  P044A060068     Santa Fe Community College         X                             

  P044A060576     Tri-County Technical College       X             X               X

  P044A060879     Seton Hall University              X                             

  P044A060642     Greater Erie Community Action      X                             
                  Committee                                                        

  P044A060674     Philadelphia Education Fund        X                             

  P044A060810     National-Louis University          X             X       X       

  P044A060104     Shelton State Community College                                  

  P044A060051     Labette Community College          X                             X

  P044A060401     University of South Alabama                                      

  P044A060052     Inter American University of       X                             X
                  Puerto Rico/San German                                           

  P044A060566     Canisius College                   X                     X       

  P044A060542     University of Notre Dame           X                             X

  P044A060207     University of Wisconsin/Milwaukee  X                             

  P044A060122     University of                      X                     X       X
                  Arkansas/Fayetteville                                            

                  **Total:**                         **16**        **2**   **7**   **8**
  --------------- ---------------------------------- ------------- ------- ------- -------

**Finding 1** OPE's awarding of prior experience points was not in
compliance with the regulations.

**Issues:** 1. OPE improperly awarded partial points.

2\. OPE did not evaluate grantees' reentry objective.

**Finding 2** OPE awarded points to grantees that did not meet minimum
program requirements

**Issue:** 1. OPE awarded points to grantees that did not meet minimum
program requirements.

**Finding 3** OPE made errors in the execution of its prior experience
points assessment.

**Issue:** 1. OPE made documentation errors.

**Finding 4** OPE changed its process for awarding prior experience
points without having the appropriate data to evaluate grantees.

Issue: 1. Grantee objectives did not correspond with the prior
experience assessment.

##   {#section .Closing}

## Appendix 3. EOC Grantees with Differences in Total Points Between the Assessment Form and Funding Slate {#appendix-3.-eoc-grantees-with-differences-in-total-points-between-the-assessment-form-and-funding-slate .Closing}

  --------------- ------------------------------------- ----------------------- -----------
                                                        **[Total PE             
                                                        Points]{.underline}**   

  **Application   **Grantee**                           **Form**                **Slate**
  No.**                                                                         

  P066A060127     Pensacola Junior College              12                      11

  P066A060284     Applied Information Management (AIM)  8                       7
                  Institute                                                     

  P066A060140     College Entrance Examination Board    9                       14

  P066A060238     Marshall University                   12                      15

  P066A060200     Northern Arizona University           13                      15

  P066A060195     University of Tennessee/Knoxville     7                       13

  P066A060243     National Scholarship Service          7                       13

  P066A060070     Arizona State University/Tempe        14.5                    15

  P066A060348     Fort Valley State University          11                      13

  P066A060373     Malcolm X College                     10.5                    15

  P066A060157     University of New Mexico              8.5                     13.5

  P066A060337     University of Washington              8                       6
  --------------- ------------------------------------- ----------------------- -----------

## Appendix 4. EOC Grantees with Point Gains Due to Math and Transcription Errors {#appendix-4.-eoc-grantees-with-point-gains-due-to-math-and-transcription-errors .Closing}

  --------------- ---------------------------------------- --------------
  **Application   **Grantee**                              **Points
  No.**                                                    Gained**

  P066A060039     Inter American University of Puerto Rico 1.0

  P066A060261     University of Pennsylvania               3.0

  P066A060224     Victoria County Junior College District  1.0

  P066A060258     Texas Southern University                1.0

  P066A060301     Colorado State University                1.5

  P066A060329     CT Talent Assistance Corp.               1.0

  P066A060214     Southwest VA Community College           0.5

  P066A060033     VA Tidewater Consortium for Higher       1.0
                  Education                                

  P066A060061     Cincinnati State Tech. and Community     1.0
                  College                                  

  P066A060262     Cuyahoga Community College               5.0

  P066A060015     North Arkansas College                   3.0

  P066A060056     Educational Partners, Inc.               3.0

  P066A060067     Mid-South Community College              2.0

  P066A060060     Eastern New Mexico University            1.0

  P066A060045     University of Kansas                     1.0

  P066A060087     University of South Carolina             1.0

  P066A060135     Shawnee State University                 0.5
  --------------- ---------------------------------------- --------------

## Appendix 5. EOC Grantees with Point Losses Due to Math and Transcription Errors {#appendix-5.-eoc-grantees-with-point-losses-due-to-math-and-transcription-errors .Closing}

  --------------- ---------------------------------------- --------------
  **Application   **Grantee**                              **Points
  No.**                                                    Lost**

  P066A060126     University of Wisconsin System/Milwaukee 3.0

  P066A060142     Halifax Community College                2.0

  P066A060057     Odessa College                           2.0

  P066A060204     Southwest Texas Junior College           1.0

  P066A060349     LEARN Inc.                               2.0

  P066A060257     Texas Association of Developing Colleges 4.0

  P066A060303     Piedmont Community College               3.0

  P066A060339     Texas State Technical College/Harlingen  1.0

  P066A060012     Rogers State University                  4.0

  P066A060157     University of New Mexico                 3.0

  P066A060172     University of Northern Iowa              3.0

  P066A060175     Creighton University                     3.0

  P066A060078     Delta Sigma Theta, Inc.                  3.0

  P066A060127     Pensacola Junior College                 2.0

  P066A060197     Palm Beach Community College             2.0

  P066A060058     Morehead State University                1.0

  P066A060255     Tougaloo College                         4.0

  P066A060284     Applied Information Management Institute 1.0

  P066A060309     Montgomery College                       1.0

  P066A060238     Marshall University                      1.0

  P066A060281     Atlanta Metropolitan College             1.0
  --------------- ---------------------------------------- --------------

![](media/image4.jpeg){width="6.527777777777778in"
height="9.052777777777777in"}

![](media/image5.jpeg){width="6.519444444444445in" height="9.11875in"}

![](media/image6.jpeg){width="6.468055555555556in"
height="9.063888888888888in"}

![](media/image7.jpeg){width="6.544444444444444in"
height="9.151388888888889in"}

![](media/image8.jpeg){width="6.536111111111111in"
height="9.140972222222222in"}

![](media/image9.jpeg){width="6.536111111111111in"
height="9.140972222222222in"}

[^1]: For example, if a hypothetical grantee in the 2002 Talent Search
    competition was funded to serve 600 participants and actually served
    450---300 of whom were low-income and potential first-generation
    college students---that grantee would receive points under Criterion
    1b, as 300 is 2/3 of the 450 participants actually served. In order
    to receive points under Criterion 1b in 2006, that grantee would
    have needed to serve at least 400 low-income and potential
    first-generation college students (2/3 of the 600 participants
    funded to serve).

[^2]: Under both programs, the Department can reduce the minimum number
    of participants a grantee is required to serve if the amount of the
    grant for the budget period is less than \$180,000. None of the
    exceptions we noted involved a grantee with a reduced participant
    number and a grant amount of less than \$180,000.

[^3]: The spreadsheet was an OPE-created document that contained the
    number of participants a grantee was funded to serve and the actual
    number it served. OPE instructed program specialists to use the
    spreadsheet as the source data for completing Criterion 1 on the
    prior experience assessment form.

[^4]: The Department can reduce the minimum number of participants a
    grantee is required to serve if the amount of the grant for the
    budget period is less than \$180,000.