Finding Text
2022-003 ? Attorney Representation Department of Health and Human Services AL # 93.600 Head Start Federal Grantor/Pass-Through Grantor Grant Number Grant Period U.S. Department of Health and Human Services 04HE00130401-C5 04/01/21 ? 03/31/23 U.S. Department of Health and Human Services 04HE00130401-C6 04/01/21 ? 03/31/23 U.S. Department of Health and Human Services 04CH01172002 02/01/21 ? 01/31/22 U.S. Department of Health and Human Services 04CH01172003 02/01/22 ? 01/31/23 Questioned Costs: None How were questioned costs computed: Not applicable Condition: At times during the year, there was no representation on the board of directors by a licensed attorney familiar with issues related to Head Start at Community Action for Improvement, Inc. When that position was vacant, the board of directors did not work with a consultant with relevant legal expertise. Criteria: The Improving Head Start for School Readiness Act of 2007 at 42 USC 9837(c)(1)(B) requires the governing body of a Head Start agency to include not less than one member with a background and expertise in fiscal management or accounting and not less than one licensed attorney familiar with issues that come before the governing body. If the types of persons described above are not available to serve as members of the governing body, the governing body must use a consultant, or another individual(s) with relevant expertise who must work directly with the governing body. Cause: Community Action for Improvement, Inc. had board vacancies during the year, causing it to not be in compliance with this requirement. Effect: Because of the above conditions, Community Action for Improvement, Inc. was not in compliance with this compliance requirement and a significant deficiency in internal control over compliance exists. Recommendation: We recommend that Community Action for Improvement, Inc. recruit an attorney for their board of directors or consult with someone with relevant expertise. View of Responsible Officials: Management agrees with the assessment and has committed to a corrective action plan.