Community Services Block Grant (CSBG)-Federal Assistance Listing Number 93.569 - Material Weakness in Internal Control over Compliance Finding 2021-004 Noncompliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding 2021-005 Noncompliance with Eligibility Recommendatio...
Community Services Block Grant (CSBG)-Federal Assistance Listing Number 93.569 - Material Weakness in Internal Control over Compliance Finding 2021-004 Noncompliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding 2021-005 Noncompliance with Eligibility Recommendation: We recommend the Organization strengthen its compliance-related internal controls by: • Requiring standardized documentation to support compliance with each requirement. • Implementing periodic reviews of documentation completeness before charging costs to federal awards. • Providing training to staff responsible for grant management on compliance and record retention requirements. • Retain all documentation related to federal awards in a central location. 35 • Reinforcing the approval process by documenting and communicating approval requirements to all staff involved in initiating and processing transactions, providing mandatory training to employees on expense authorization policies, and establishing monitoring procedures to ensure approvals are consistently documented before transactions are processed. Management agrees with the finding and the recommendation. During the audit period in the following years until present, STOP’s clear policy and practice was to only provide service to individuals and families whose annual income does not exceed the established threshold on the federal poverty guidelines as published annually. While documentation was deficient to demonstrate eligibility for a small number of the total files sampled, the missing documentation is not an indicator that ineligible applicants received services. To address the root causes, the following actions have been implemented: The Organization has implemented Bill.com Accounts Payable workflow and document retention platform. Wipfli, LLP was engaged for accounting services in August of 2023 and subsequently, implemented Bill.com to facilitate accounts payable approval processes and document retention. The software has established hierarchies built within the system to ensure all invoices are properly reviewed and approved prior to processing. All staff included in the approval process were trained to utilize the system for processing. Wipfli staff is engaged for the accounts payable processing activities in the system. All STOP staff have or will participate in annual in-service training and will be provided updated eligibility criteria annually. This ensures that all staff have proper information and adheres to the federally published poverty guidelines and that agency practices of only providing services to individuals who meet the established criteria are provided services. Additionally, all files will include an eligibility checklist outlining all documents needed to support eligibility and will also include a compliance reviewer signature. This should ensure that all files are complete and have necessary documentation to support eligibility. Completion Date: December 2025