Finding Text
Federal Program: Community Services Block Grant (CSBG) – ALN 93.569
Compliance Requirement: Eligibility and Allowable Activities/Costs
Type of Finding: Compliance and Internal Control Deficiency
Condition:
During our review of client case files under the CSBG program, we identified an instance in which services and benefits were provided to a single individual rather than to the household unit, contrary to CSBG program requirements. The intake documentation did not reflect an evaluation or approval at the household level, and the assistance was recorded and delivered as though the individual were the sole service recipient.
Under CSBG guidance, eligibility and service determinations are required to be made at the household level, as the program is designed to address the needs of low-income families, not isolated individuals within those families.
Criteria:
Per 45 CFR §96.30(a) and the U.S. Department of Health and Human Services CSBG Terms and Conditions, recipients must establish eligibility based on household income and provide services that are consistent with the needs of the family unit. In addition, the OMB Compliance Supplement for ALN 93.569 emphasizes that services must be targeted to eligible households to meet statutory intent and federal program objectives.
Cause:
The condition appears to have resulted from an oversight in case management procedures and a lack of clarity in intake protocols regarding the requirement to document and apply eligibility and benefits at the household level.
Effect:
Failure to assess and deliver services at the household level may result in noncompliance with CSBG program requirements and introduces the risk of inconsistent or inequitable benefit distribution among clients. If not addressed, this weakness may lead to systemic misapplication of eligibility standards.
Recommendation:
We recommend that STDC take the following steps to ensure compliance with CSBG eligibility and service delivery requirements:
• Reinforce federal guidance through staff training for intake personnel and case managers, emphasizing that services must be assessed and provided based on household eligibility;
• Update intake procedures and forms to ensure complete documentation of household composition, income, and eligibility status;
• Implement periodic internal file reviews to verify that household-level eligibility determinations are consistently applied and properly documented in client records.
Questioned Costs: None (isolated instance)