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Finding 2025-001 Community Services Block Grant - Tripartite Board Composition Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Florida Department of Commerce Assistance Listing: 93.569 - Community Services Block Grant Compliance Requirement: Special Tests and Provisions Classification: Significant Deficiency in Internal Control over Compliance and Noncompliance Questioned Costs: None Criteria The Community Services Block Grant Act requires nonprofit eligible entities to administer CSBG through a tripartite board consisting of one-third public representatives or qualifying designees, not fewer than one-third representatives of low-income individuals and families selected through an appropriate democratic selection process, with the remaining members representing major groups and interests in the community served. The 2025 Compliance Supplement provides that when vacancies reduce public or low-income representation below the required threshold and remain vacant longer than the period permitted by the state, the auditor should report a finding. Condition During the year ended September 30, 2025, NFCAA did not maintain the required tripartite board composition. The August 2025 Board of Directors roster listed 16 members: four public-sector representatives, five low-income representatives, and seven private-sector representatives. Accordingly, public-sector representation was 25% and low-income representation was 31.25%, both below the required one-third threshold. Certain public-sector vacancies remained unfilled for more than 90 days, exceeding the assumed 90-day period permitted by the Florida Department of Commerce. Cause NFCAA experienced difficulty obtaining and timely seating qualified representatives, particularly public-sector representatives. In addition, procedures for monitoring board composition and vacancy duration were not sufficiently effective to ensure that required representation was restored within the period permitted by the Florida Department of Commerce. Effect NFCAA did not maintain the required tripartite board representation during a portion of the audit period. Inadequate monitoring of board composition increases the risk that vacancies will cause required public-sector or low-income representation to remain below statutory thresholds beyond the period permitted by the pass-through entity.