Audit 355262

FY End
2024-09-30
Total Expended
$14.27M
Findings
2
Programs
9
Year: 2024 Accepted: 2025-05-01

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
559014 2024-001 Significant Deficiency - E
1135456 2024-001 Significant Deficiency - E

Contacts

Name Title Type
KVHVANJMNKZ6 Mark Kurtz Auditee
3144464410 Katie Zahner Auditor
No contacts on file

Notes to SEFA

Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Y Rate Explanation: Community Action Agency of St. Louis County, Inc. has elected to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance.

Finding Details

Major Program: Community Service Block Grant AL #93.569 Compliance Requirement: Eligibility Questioned Costs: None Type of Finding: Significant Deficiency in Internal Control over Compliance of Major Programs Criteria: The Community Action Agency must establish and maintain effective internal control over federal awards that provides reasonable assurance of compliance with applicable federal statutes, regulations, and the terms and conditions of the award, in accordance with 2 CFR §200.303. For the eligibility compliance requirement, documentation must clearly demonstrate that eligibility was determined prior to the provision of benefits, and that all required approvals were contemporaneously documented. Condition: During eligibility testing, it was identified that one intake form out of a sample of 40 exhibited a discrepancy in the timing of documentation completion and staff review. Specifically, for a client who received food pantry services on January 25, 2024, the client received and signed the Food Pantry Service Sheet on that same day, confirming eligibility determination. However, the CAASTLC staff member did not sign the form until January 31, 2024, several days after the client had received services. The MIS intake report reflects a date of February 2, 2024, which corresponds to when the data was entered into the system, rather than the date eligibility was actually determine. Cause: The procedures in place prioritized maintaining traffic flow during drive-through food pantry operations over contemporaneous documentation practices. As a result, the staff review and signature confirming eligibility were delayed and not completed on the date of service. Effect: Although eligibility was assessed and determined prior to the provision of services, the absence of timely staff signatures weakens the audit trail. This increases the risk that services may be provided without proper approval or that documentation may not adequately support compliance with eligibility requirements during an audit or program review. Recommendation: The Organization should strengthen internal controls and provide additional staff training to ensure all eligibility documentation—including staff review and signatures—is completed contemporaneously with client service. Where operational constraints exist, the Organization should consider implementing procedures to document eligibility determinations in real-time, or adopt digital tools to capture staff approval at the point of intake. View of Responsible Officials: See Corrective Action Plan.
Major Program: Community Service Block Grant AL #93.569 Compliance Requirement: Eligibility Questioned Costs: None Type of Finding: Significant Deficiency in Internal Control over Compliance of Major Programs Criteria: The Community Action Agency must establish and maintain effective internal control over federal awards that provides reasonable assurance of compliance with applicable federal statutes, regulations, and the terms and conditions of the award, in accordance with 2 CFR §200.303. For the eligibility compliance requirement, documentation must clearly demonstrate that eligibility was determined prior to the provision of benefits, and that all required approvals were contemporaneously documented. Condition: During eligibility testing, it was identified that one intake form out of a sample of 40 exhibited a discrepancy in the timing of documentation completion and staff review. Specifically, for a client who received food pantry services on January 25, 2024, the client received and signed the Food Pantry Service Sheet on that same day, confirming eligibility determination. However, the CAASTLC staff member did not sign the form until January 31, 2024, several days after the client had received services. The MIS intake report reflects a date of February 2, 2024, which corresponds to when the data was entered into the system, rather than the date eligibility was actually determine. Cause: The procedures in place prioritized maintaining traffic flow during drive-through food pantry operations over contemporaneous documentation practices. As a result, the staff review and signature confirming eligibility were delayed and not completed on the date of service. Effect: Although eligibility was assessed and determined prior to the provision of services, the absence of timely staff signatures weakens the audit trail. This increases the risk that services may be provided without proper approval or that documentation may not adequately support compliance with eligibility requirements during an audit or program review. Recommendation: The Organization should strengthen internal controls and provide additional staff training to ensure all eligibility documentation—including staff review and signatures—is completed contemporaneously with client service. Where operational constraints exist, the Organization should consider implementing procedures to document eligibility determinations in real-time, or adopt digital tools to capture staff approval at the point of intake. View of Responsible Officials: See Corrective Action Plan.