COMMUNITY ACTION AGENCY OF ST. LOUIS COUNTY, INC.Non-Profit

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.

Questioned Costs: None Condition: During our audit, Wipfli tested 25 participant files and their associated disbursements related to this grant award. Of the 25 disbursements, one was not paid within 45 days of the date of crisis. All transactions tested were for services provided that are allowable to be charged to the grant award. Criteria: A requirement of the LIHEAP manual from the State of Missouri Department of Social Services Family Support Division indicates that payments must be issued no later than 45 calendar days after an eligible household applied for assistance or 45 days from the date of crisis if it differs from and occurs later than the application date. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan. Recommendation: We recommend that CAASTLC review their procedures for monitoring outstanding invoices so that vendors can be consistently paid within 45 days of the date of crisis or application date. Effect: As a result of the compliance matter identified in the condition paragraph, a significant deficiency exists in CAASTLC?s compliance of the major program. Cause: CAASTLC lacked adequate fiscal oversight to ensure all vendors were paid consistently within 45 days. View of responsible officials: Management agrees with the assessment and has committed to a corrective action plan.

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