CORRECTIVE ACTION PLAN — Finding 2025-001 Compliance Finding – Special Tests and Provisions | Community Services Block Grant (ALN 93.569) Entity: Southeastern Vermont Community Action, Inc. (SEVCA) | Pass-Through Entity: State of Vermont Department for Children and Families | Cognizant Federal Agenc...
CORRECTIVE ACTION PLAN — Finding 2025-001 Compliance Finding – Special Tests and Provisions | Community Services Block Grant (ALN 93.569) Entity: Southeastern Vermont Community Action, Inc. (SEVCA) | Pass-Through Entity: State of Vermont Department for Children and Families | Cognizant Federal Agency: U.S. Department of Health and Human Services | CAP Contact: Joshua Davis, Executive Director, JDavis@sevca.org 1. Summary of Finding Finding 2025-001 identified that, as of the September 24, 2025 board meeting, SEVCA’s 13-member Board of Directors did not meet the required CSBG tripartite composition: four participant-sector members, five private-sector members, and four public-sector members, leaving neither the participant nor the public sector at one-third. SEVCA returned to compliance the following month by seating the additional members needed to restore the required composition, recruited and seated through SEVCA’s established board-selection process. No questioned costs were identified. 2. Management’s Response SEVCA concurs with the finding. The tripartite structure is fundamental to community action agency governance and to meaningful representation of low-income individuals and families, public officials, and private-sector members. Management and the Board have strengthened monitoring of Board composition and are maintaining a continuing pipeline of prospective members in each required sector. 3. Root Cause Board-member turnover created a temporary imbalance among the three required sectors. The underlying control gap was the absence of a documented composition matrix, a recurring compliance review, and a formal escalation procedure triggered when a departure caused—or was expected to cause—a sector to fall below its required representation. Because members must be seated through SEVCA’s established selection procedures, vacancies cannot always be filled immediately, making proactive succession planning and sector-specific recruitment necessary. 4. Corrective Actions 1. Provide Board training on CSBG tripartite composition requirements and each member’s role in maintaining a compliant Board — Executive Director / Board Chair; completed and incorporated into ongoing Board education. 2. Maintain a Board composition matrix identifying each member’s sector, term dates, appointing or selecting authority, applicable public-official status, and current or anticipated vacancies — Executive Director / Board Secretary; completed and maintained ongoing. 3. Review the composition matrix at each regular Executive Committee meeting, include it in the monthly Board meeting materials, and document the review in the minutes — Board Chair / Executive Director; ongoing. 4. Maintain an all-Board recruitment pipeline of qualified candidates for each required sector through public advertising, community partnerships, and direct outreach, beginning recruitment as early as possible when a departure is anticipated — Board of Directors / Executive Director; implemented and ongoing. 5. Adopt written requirements that vacancies affecting tripartite compliance be filled within 90 days where reasonably possible, with immediate escalation of any current or anticipated imbalance to the Board Chair and governance committee, together with contingency procedures for declined appointments, failed elections, or mid-year changes in Board size — Executive Committee; within 90 days of plan approval. 6. Obtain an annual certification by the Board Chair or governance committee confirming tripartite composition compliance and documentation of member-selection procedures — Board Chair / Governance Leadership; annually, beginning with the next governance review. 5. Anticipated Completion Date Restoration of tripartite compliance, Board training, and the composition matrix are complete. Written vacancy, escalation, and contingency requirements will be completed within 90 days of approval of this plan. Recruitment, succession planning, composition monitoring, and annual certification continue as ongoing governance responsibilities. 6. Monitoring The Executive Director and Board Chair will monitor the composition matrix, review it at each regular Executive Committee meeting, and include it with the monthly Board meeting materials. Progress toward filling affected seats will be reported to the full Board until compliance is restored, and the Board Chair or Executive Committee will complete the annual composition certification.