Finding 279108 (2022-001)

-
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-07-05
Audit: 265973
Auditor: Wipfli LLP

AI Summary

  • Core Issue: CAP Services, Inc. did not have at least one-third of its board members representing low-income individuals and families, violating the Tri-Partite board requirement.
  • Impacted Requirements: This situation breaches the CSBG Act, which mandates that public organizations maintain a compliant board composition.
  • Recommended Follow-Up: CAP Services, Inc. should implement procedures to ensure board composition meets legal requirements and has committed to a corrective action plan.

Finding Text

2022-001 ? Tri-Partite Board Composition Department of Health and Human Services AL # 93.569 Community Services Block Grant Federal Grantor/Pass-Through Grantor Grant Number Wisconsin Department of Children & Families 437004-G22-0001953-000-02 Wisconsin Department of Children & Families 437004-G20-0001632-000-02 Questioned Costs: None How were questioned costs computed: Not applicable Condition: At times during the year, less than 1/3 of the members of the board of directors of CAP Services, Inc. were representative of the low-income individuals and families served by the Organization. Criteria: The CSBG Act at 42 USC 9910(b), requires that public organizations administer CSBG through a Tri-Partite board. This board shall have members selected by the organization and shall be composed so as to assure that no less than one-third (1/3) of the members are representative of the individuals and families served by the organization. Cause: CAP Services, Inc. had board vacancies during the year, causing it to not be in compliance with the tripartite board requirement. Effect: Because of the above conditions, CAP Services, Inc. was not in compliance with this compliance requirement. Recommendation: We recommend that CAP Services, Inc. establish procedures to ensure the composition of the members of its board of directors meets this requirement. View of Responsible Officials: Management agrees with the assessment and has committed to a corrective action plan.

Corrective Action Plan

CAP Services, Inc. submits the following corrective action plan for the identified finding for the audit period January 1, 2022 through December 31, 2022: Finding 2022-001 Tri-Partite Board Composition As stated in CAP's bylaws, the composition of CAP's Board of Directors requires tri-partite representation from three sectors: low-income community, community at large, and public elected officials. CAP is the locally designated community action agency for five counties. The Board composition includes four members from each county and one member elected by CAP's Head Start Policy Council for a total of twenty-one members. One-third (7 of 21) represent each of the three sectors. In 2022, CAP experienced two unexpected resignations of low-income representatives during the course of the year and retained the remaining nineteen members. As a result of the vacancies, the one-third representation was not met as the remaining members were actively engaged in their respective seats (average 90% participation). Recruitment was ongoing and several low-income community members expressed interest in the seats, however, the continued uncertainty of the ongoing pandemic was a challenge and a barrier. Corrective Action Plan for Future: ? CAP's Governance Committee will take a more active role in recruitment and retention of Board members. ? CAP's executive team will maintain a list of interested candidates and send regular communication to keep candidates engaged and ready if a seat becomes available. ? CAP's bylaws will be reviewed for consideration of shifting designated seats to offer more flexibility that will better ensure at least one-third low-income representation when unexpected vacancies occur. ? CAP will consult with other community action agencies and the National Community Action Partnership to explore best practices related to recruitment of low-income representatives. As of the date of this letter, CAP's 21-member Board of Directors is fully seated and meets the tri-partite board requirement.

Categories

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Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
16.575 Crime Victim Assistance $949,465
21.024 Community Development Financial Institutions Rapid Response Program (cdfi Rrp) $741,395
10.415 Rural Rental Housing Loans $670,141
93.568 Low-Income Home Energy Assistance $501,550
93.569 Community Services Block Grant $377,104
81.042 Weatherization Assistance for Low-Income Persons $369,396
14.239 Home Investment Partnerships Program $339,648
93.600 Head Start $311,521
21.023 Emergency Rental Assistance Program $244,307
21.027 Coronavirus State and Local Fiscal Recovery Funds $233,512
14.856 Lower Income Housing Assistance Program_section 8 Moderate Rehabilitation $226,755
10.558 Child and Adult Care Food Program $222,381
59.046 Microloan Program $220,668
20.509 Formula Grants for Rural Areas and Tribal Transit Program $120,552
93.268 Immunization Cooperative Agreements $92,405
10.427 Rural Rental Assistance Payments $86,430
10.870 Rural Microentrepreneur Assistance Program $72,130
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $45,451
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $39,105
93.623 Basic Center Grant $36,850
93.557 Education and Prevention Grants to Reduce Sexual Abuse of Runaway, Homeless and Street Youth $32,612
21.025 Small Dollar Loan Program $30,719
93.645 Stephanie Tubbs Jones Child Welfare Services Program $22,500
14.252 Section 4 Capacity Building for Community Development and Affordable Housing $19,020
14.218 Community Development Block Grants/entitlement Grants $10,441
93.556 Promoting Safe and Stable Families $8,550
97.024 Emergency Food and Shelter National Board Program $3,750