Finding 559014 (2024-001)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-05-01

AI Summary

  • Core Issue: There is a significant deficiency in internal controls regarding eligibility documentation for the Community Service Block Grant.
  • Impacted Requirements: Eligibility must be determined and documented before services are provided, as per federal regulations.
  • Recommended Follow-Up: Enhance internal controls and train staff to ensure timely documentation and signatures are completed at the time of service delivery.

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.

Corrective Action Plan

CAASTLC acknowledges the timing discrepancy in the documentation of staff review and signature during the drive-through food pantry operations in early 2024. Although eligibility was appropriately determined prior to the distribution of food, we recognize the importance of ensuring that all related documentation is contemporaneously completed and appropriately approved to maintain a strong internal control environment. The current intake and eligibility verification procedures was revised to include explicit language requiring staff signatures and approval of eligibility documentation on the date of service. These updated procedures will reflect both in-office and drive-through (if resumed) operations. All relevant staff members will receive updated training on intake documentation requirements, including the importance of contemporaneous staff review and approval. Training materials will be revised to emphasize compliance with federal requirements related to eligibility documentation. While data entry into MIS may still occur post-service, staff will be required to document and date eligibility approvals on the intake fonns at the time of service. Intake forms will now include a section for immediate staff verification with date stamps to reflect real-time approval. Name of Responsible Person: Linda Huntspon, Chief Executive Officer Anticipated Completion Date: Implemented in January 31, 2025

Categories

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1135456 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.569 Community Services Block Grant $2.08M
21.027 Coronavirus State and Local Fiscal Recovery Funds $876,356
10.569 Emergency Food Assistance Program (food Commodities) $396,131
81.042 Weatherization Assistance for Low-Income Persons $167,992
93.558 Temporary Assistance for Needy Families $136,770
93.568 Low-Income Home Energy Assistance $120,000
97.024 Emergency Food and Shelter National Board Program $82,687
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $22,092
14.218 Community Development Block Grants/entitlement Grants $117