Finding Text
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.