STDC acknowledges the finding regarding the provision of CSBG-funded services to an individual without verifying household-level eligibility. While this was an isolated incident, it represents a deviation from both federal CSBG guidance (Office of Community Services CSBG Informational Memorandum 139 [OCS IM-149]) and STDC’s internal case management procedures, which require eligibility and service assessments at both the household and individual level.
STDC has identified this as a training and documentation oversight. As a result, we are reinforcing compliance through mandatory case management refresher training, enhanced supervision, and internal file reviews to ensure consistent application of household-based eligibility protocols.
Corrective Action Plan
Finding Number: 2023-03
Planned Completion Date: September 30, 2025
Responsible Official: Community Action Program Manager
Corrective Actions to Be Implemented:
1. Mandatory Refresher Training
All Community Action Program (CAP) Case managers and intake staff will complete a refresher training on: OCS IM-149 “Strengthening Outcome Through Two-Generation Approaches”; Existing STDC Case Management standards and intake procedures; and proper documentation of household and individual case notes. Trainings will be held annually and during onboarding for new hires.
2. Standard Operating Procedure (SOP) Reinforcement
Supervisors will reinforce the use of STDC’s CAP standardized intake, eligibility, and case management forms. Clear instructions will be recirculated to all case managers on verifying and recording household information. In instances where an eligible households is declining additional services, Case Managers will obtain signed affidavits from the individuals declining services or participation.
3. Case Management Packet Review and Update
Case Management forms will be reviewed and updated, if needed, to ensure required fields for household size, income, and composition are clearly marked and completed prior to service approval. A standardized affidavit where individuals are declining services or participation in eligible households shall be created to document client refusal of services.
4. Internal Monitoring Protocol
The CAP Program Manager will conduct quarterly reviews of a sample of client files to verify household-based eligibility and client file documentation standards. Any deviation will trigger corrective coaching and documentation of follow-up.
5. Documentation Audit Trail
All CAP client records must include:
o Completed household intake form;
o Income verification and eligibility determination;
o Corresponding service delivery/case management service authorizations, service delivery plans, and notes.
Files lacking required documentation will be flagged and corrected. Continued deficiencies from Case Managers will be noted on annual performance evaluations with individualized employee improvement plans.