2024‐001 – HeadStart Cluster, AL# 93.600, Activities Allowed/Unallowed
Condition: Included in HeadStart expenditures for 2024 are amounts that are believed to be fraudulently expended and
not for their intended use. In some instances, the funds were disbursed without proper authorization, primarily through
use of Agency credit cards. In other instances, co‐payments for HeadStart services were not properly remitted for deposit,
resulting in the need to use additional Federal funds to cover costs.
Criteria: All expenditures are to be properly authorized, and all funds are to be properly remitted for deposit. The Agency
does have policies in place requiring these to occur.
Cause: Employees acted outside the policies and procedures in place to misappropriate funds.
Effect: HeadStart funds were not used for their intended purpose.
Questioned Cost Amount: Final amounts to be determined.
Perspective Information: N/A
Recommendation: While HeadStart has review and approval policies in place, we recommend that they continue to look
for ways to tighten policies and procedures around agency card use and remittance of funds for deposit. Any additional
segregation of processes that can be feasibly made should be taken.
Views of Responsible Officials and Planned Corrective Action: 1) We have and will be working closely with our HR and
Head Start attorneys to recoup as much of the potentially fraudulent charges as possible and for guidance in communication with the
persons involved. The Head Start Attorney suggested we retain forensic accountants to conduct a fraud audit of all TAP
Head Start financial records. The accountants have been retained and are beginning work.
2) We will create policies to require detailed explanation of meal purchases, prohibit TAP credit card use for purchases
from personal on‐line accounts, and address any additional issues the auditors may find. Our junior staff accountant will
review credit card payment vouchers for compliance.
3) A separate object code (account) will be created in our accounting software where all gift card purchases will be coded.
Our accounts payable clerks will submit copies of any gift card charges to our junior staff accountant, who will be
responsible for reviewing and verifying that all required documentation is included (as required in Gift Card policies on
TAP’s accounting manual).
4) Copies of Center receipt logs for parent payments will be submitted to Finance where they will be reconciled by the Head
Start Finance Director to funds remitted.
2024‐001 – HeadStart Cluster, AL# 93.600, Activities Allowed/Unallowed
Condition: Included in HeadStart expenditures for 2024 are amounts that are believed to be fraudulently expended and
not for their intended use. In some instances, the funds were disbursed without proper authorization, primarily through
use of Agency credit cards. In other instances, co‐payments for HeadStart services were not properly remitted for deposit,
resulting in the need to use additional Federal funds to cover costs.
Criteria: All expenditures are to be properly authorized, and all funds are to be properly remitted for deposit. The Agency
does have policies in place requiring these to occur.
Cause: Employees acted outside the policies and procedures in place to misappropriate funds.
Effect: HeadStart funds were not used for their intended purpose.
Questioned Cost Amount: Final amounts to be determined.
Perspective Information: N/A
Recommendation: While HeadStart has review and approval policies in place, we recommend that they continue to look
for ways to tighten policies and procedures around agency card use and remittance of funds for deposit. Any additional
segregation of processes that can be feasibly made should be taken.
Views of Responsible Officials and Planned Corrective Action: 1) We have and will be working closely with our HR and
Head Start attorneys to recoup as much of the potentially fraudulent charges as possible and for guidance in communication with the
persons involved. The Head Start Attorney suggested we retain forensic accountants to conduct a fraud audit of all TAP
Head Start financial records. The accountants have been retained and are beginning work.
2) We will create policies to require detailed explanation of meal purchases, prohibit TAP credit card use for purchases
from personal on‐line accounts, and address any additional issues the auditors may find. Our junior staff accountant will
review credit card payment vouchers for compliance.
3) A separate object code (account) will be created in our accounting software where all gift card purchases will be coded.
Our accounts payable clerks will submit copies of any gift card charges to our junior staff accountant, who will be
responsible for reviewing and verifying that all required documentation is included (as required in Gift Card policies on
TAP’s accounting manual).
4) Copies of Center receipt logs for parent payments will be submitted to Finance where they will be reconciled by the Head
Start Finance Director to funds remitted.
2024‐001 – HeadStart Cluster, AL# 93.600, Activities Allowed/Unallowed
Condition: Included in HeadStart expenditures for 2024 are amounts that are believed to be fraudulently expended and
not for their intended use. In some instances, the funds were disbursed without proper authorization, primarily through
use of Agency credit cards. In other instances, co‐payments for HeadStart services were not properly remitted for deposit,
resulting in the need to use additional Federal funds to cover costs.
Criteria: All expenditures are to be properly authorized, and all funds are to be properly remitted for deposit. The Agency
does have policies in place requiring these to occur.
Cause: Employees acted outside the policies and procedures in place to misappropriate funds.
Effect: HeadStart funds were not used for their intended purpose.
Questioned Cost Amount: Final amounts to be determined.
Perspective Information: N/A
Recommendation: While HeadStart has review and approval policies in place, we recommend that they continue to look
for ways to tighten policies and procedures around agency card use and remittance of funds for deposit. Any additional
segregation of processes that can be feasibly made should be taken.
Views of Responsible Officials and Planned Corrective Action: 1) We have and will be working closely with our HR and
Head Start attorneys to recoup as much of the potentially fraudulent charges as possible and for guidance in communication with the
persons involved. The Head Start Attorney suggested we retain forensic accountants to conduct a fraud audit of all TAP
Head Start financial records. The accountants have been retained and are beginning work.
2) We will create policies to require detailed explanation of meal purchases, prohibit TAP credit card use for purchases
from personal on‐line accounts, and address any additional issues the auditors may find. Our junior staff accountant will
review credit card payment vouchers for compliance.
3) A separate object code (account) will be created in our accounting software where all gift card purchases will be coded.
Our accounts payable clerks will submit copies of any gift card charges to our junior staff accountant, who will be
responsible for reviewing and verifying that all required documentation is included (as required in Gift Card policies on
TAP’s accounting manual).
4) Copies of Center receipt logs for parent payments will be submitted to Finance where they will be reconciled by the Head
Start Finance Director to funds remitted.
2024‐001 – HeadStart Cluster, AL# 93.600, Activities Allowed/Unallowed
Condition: Included in HeadStart expenditures for 2024 are amounts that are believed to be fraudulently expended and
not for their intended use. In some instances, the funds were disbursed without proper authorization, primarily through
use of Agency credit cards. In other instances, co‐payments for HeadStart services were not properly remitted for deposit,
resulting in the need to use additional Federal funds to cover costs.
Criteria: All expenditures are to be properly authorized, and all funds are to be properly remitted for deposit. The Agency
does have policies in place requiring these to occur.
Cause: Employees acted outside the policies and procedures in place to misappropriate funds.
Effect: HeadStart funds were not used for their intended purpose.
Questioned Cost Amount: Final amounts to be determined.
Perspective Information: N/A
Recommendation: While HeadStart has review and approval policies in place, we recommend that they continue to look
for ways to tighten policies and procedures around agency card use and remittance of funds for deposit. Any additional
segregation of processes that can be feasibly made should be taken.
Views of Responsible Officials and Planned Corrective Action: 1) We have and will be working closely with our HR and
Head Start attorneys to recoup as much of the potentially fraudulent charges as possible and for guidance in communication with the
persons involved. The Head Start Attorney suggested we retain forensic accountants to conduct a fraud audit of all TAP
Head Start financial records. The accountants have been retained and are beginning work.
2) We will create policies to require detailed explanation of meal purchases, prohibit TAP credit card use for purchases
from personal on‐line accounts, and address any additional issues the auditors may find. Our junior staff accountant will
review credit card payment vouchers for compliance.
3) A separate object code (account) will be created in our accounting software where all gift card purchases will be coded.
Our accounts payable clerks will submit copies of any gift card charges to our junior staff accountant, who will be
responsible for reviewing and verifying that all required documentation is included (as required in Gift Card policies on
TAP’s accounting manual).
4) Copies of Center receipt logs for parent payments will be submitted to Finance where they will be reconciled by the Head
Start Finance Director to funds remitted.