Finding 8291 (2023-001)

Significant Deficiency

Requirement

Questioned Costs

Year

2023

Accepted

2024-01-11

Audit: 11088

Organization: People's Community Action Corporation (MO)

Auditor: Cohnreznick LLP

AI Summary

Core Issue: The Organization lacked proper documentation to verify client eligibility based on federal guidelines.
Impacted Requirements: Compliance with U.S. Department of Health and Human Services eligibility criteria was not met.
Recommended Follow-Up: Implement stronger internal controls to ensure all in-take forms and supporting documents are accurately reviewed and documented.

Finding Text

Finding 2023.001: Eligibility Documentation Grantor: U.S. Department of Health and Human Services Federal Program Names: Community Services Block Grant COVID-19 Community Services Block Grant Federal Assistance Listing Number: 93.569 Criteria Organizations are required to follow the official guidelines as revised annually by U.S. Department of Health and Human Services under the authority of 42 U.S.C. 9902(2) to determine eligibility. The Organization should be implementing and monitoring procedures to properly determine, calculate and review in-take forms for eligible clients in accordance with the official poverty guidelines, as revised annually by DHHS. Condition The Organization did not always have the proper documentation to ensure in-take forms were reviewed for proper eligibility based on the official guidelines. Cause The Organization did not have adequate internal controls in place to effectively ensure that all income levels were properly calculated based on approved documentation. Context A test of 25 eligible clients was performed and resulted in five instances of eligibility internal controls not being properly documented. Our sample was a statistically valid sample. Questioned Costs None. Effect The Organization did not comply with the appropriate rules and regulations as per the Uniform Guidance. Identification of Repeat Finding No. Recommendation The Organization should establish a system of internal controls to ensure that all eligible client in-take forms and supporting documentation is appropriate and properly documented. Views of Responsible Officials Management agrees with the audit finding and will strengthen internal controls and accountability to correct the deficiency.

Corrective Action Plan

United Stated Department of Health and Human Services People's Community Action Corporation respectfully submits the following corrective action plan for the year ended May 31, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: May 31, 2023 The findings from the May 31, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS SIGNIFICANT DEFICIENCY 2023.001 - Eliqibilitv Documentation Recommendation The Organization should establish a system of internal controls to ensure that all eligible clients intake forms and supporting documentation is appropriate and properly documented. Action Taken PCAC already has the appropriate policies and procedures in place through its Community Services Block Grant (CSBG) Policies and Procedures Manual. None of the client Intake Applications cited for failure to have a PCAC representative signature were completed by regular CSBG employees, but instead by employees with other duties, interns, and volunteers who assisted with acceptance of Intake Applications and data entry in times of heavy workloads for regular CSBG employees. Accordingly, PCAC leadership will take the following steps to ensure that proper procedures are followed. • Remedial training regarding the policy of requiring a PCAC representative signature on Intake Applications will be provided to all regular CSBG employees at the October 10, 2023, PCAC all-staff meeting, and individually to any of those employees who are not able to attend that meeting. • Emphasis in this remedial training will focus on the need to train non-CSBG employees, interns, and volunteers who accept Intake Applications in support of regular CSBG employees during times of heavy workloads on the requirement for a PCAC representative signature on all Intake Applications. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Mark Sanford, Executive Director at 314.367.7848 x 1209.

Other Findings in this Audit

8292 2023-001

Significant Deficiency
584733 2023-001

Significant Deficiency
584734 2023-001

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
93.569	Community Services Block Grant	$1.48M
21.027	Coronavirus State and Local Fiscal Recovery Funds	$109,000