EIN: 741537786
UEI: GSA_MIGRATION
Audited by: BANKOLE, OKOYE & ASSOCIATES PC
Oversight agency: 93 [Department of Health and Human Services]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 29, 2022. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 1, 2023 (1277 days ago).
What is a management decision? →AUDIT FINDING REFERENCE No. 2021?001 ? A Repeat Finding: Federal Department: U.S. Department of Health and Human Services Program Name: Low-Income Home Energy Assistance Program - Operated as Comprehensive Energy Assistance Program (CEAP) Assistance Listing No. 93.568 Compliance Requirement: Matching, Level of Effort, Earmarking CRITERIA: The Council?s CEAP program contract delineated the program?s total budget for the year into three main expenditure categories, namely (1) direct services to clients ? 80.44%, (2) program services expenses ? 12.33%, and (3) program administration expenses ? 7.23%. The contract required the Council to incur program expenses in the ratio of the percentages shown in this paragraph. CONDITION: During the fiscal year ended November 30, 2021, the Council exceeded the allowable proportionate share of the budget for program services expenses and program administration expenses. To pay for these extra expenses, the Council drew program funds in excess of the limits for administration and program services. These excess draws did not meet the criteria to be recorded as grant revenues. Accordingly, they are reported as advances that are refundable to the funding agency. As of November 30, 2021, a total of $638,934 has been recorded as an advance that is refundable to the funding agency (this amount includes the $510,583 carried forward from the prior year that was reported in the prior year audit finding). CAUSE: The Council did not achieve program outreach and client in-take targets and was unable to earn sufficient program revenues to offset its operational expenses. EFFECT: Total of $638,934 of CEAP program expenditures did not meet the criteria for allowable expenditures and have been reported as refundable program advances in the Council?s financial statements. RECOMMENDATION: The Council should establish processes and controls to ensure timely suspension or termination of any program that is not generating sufficient revenues to cover the program?s operational costs.
Show full finding ▾Hide full finding ▴AUDIT FINDING REFERENCE No. 2021?001 ? A Repeat Finding: Federal Department: U.S. Department of Health and Human Services Program Name: Low-Income Home Energy Assistance Program - Operated as Comprehensive Energy Assistance Program (CEAP) Assistance Listing No. 93.568 Compliance Requirement: Matching, Level of Effort, Earmarking CRITERIA: The Council?s CEAP program contract delineated the program?s total budget for the year into three main expenditure categories, namely (1) direct services to clients ? 80.44%, (2) program services expenses ? 12.33%, and (3) program administration expenses ? 7.23%. The contract required the Council to incur program expenses in the ratio of the percentages shown in this paragraph. CONDITION: During the fiscal year ended November 30, 2021, the Council exceeded the allowable proportionate share of the budget for program services expenses and program administration expenses. To pay for these extra expenses, the Council drew program funds in excess of the limits for administration and program services. These excess draws did not meet the criteria to be recorded as grant revenues. Accordingly, they are reported as advances that are refundable to the funding agency. As of November 30, 2021, a total of $638,934 has been recorded as an advance that is refundable to the funding agency (this amount includes the $510,583 carried forward from the prior year that was reported in the prior year audit finding). CAUSE: The Council did not achieve program outreach and client in-take targets and was unable to earn sufficient program revenues to offset its operational expenses. EFFECT: Total of $638,934 of CEAP program expenditures did not meet the criteria for allowable expenditures and have been reported as refundable program advances in the Council?s financial statements. RECOMMENDATION: The Council should establish processes and controls to ensure timely suspension or termination of any program that is not generating sufficient revenues to cover the program?s operational costs.
The agency agrees with the audit finding for fiscal year ended November 2021. The agency has incorporated and communicated changes in our policies and procedures to ensure timely tracking of program expenditures. The agency has begun the process of working with accounting personnel to track each program expenditure on a weekly basis and matching the expenditures to the approved budget for each program on a monthly basis. The Board members review and approve the monthly revenue and expenditure report. The agency plans to continue this process for each program until the completion/expiry of each program.
2020-001
AUDIT FINDING REFERENCE No. 2021?002: Federal Department: U.S. Department of Health and Human Services Program Name: Community Services Block Grant (CSBG) Assistance Listing No. 93.569 Program Name: Low-Income Home Energy Assistance Program - Operated as Comprehensive Energy Assistance Program (CEAP) Assistance Listing No. 93.568 Compliance Requirement: Eligibility Documentations CRITERIA: LIHEAP and CSBG statutes establish client eligibility criteria as well as requirements to verify clients? income as part of the eligibility criteria. Accordingly, federal regulations require the Council to maintain records sufficient to document client eligibility and need for receiving benefits under these program. CONDITION: CSBG - Out of 25 unduplicated samples of program beneficiaries, the Council was unable to produce the folders maintained for 2 beneficiaries, in which eligibility information was maintained. LIHEAP ? Out of 25 unduplicated samples of program beneficiaries, the Council was unable to produce the folders maintained for 3 beneficiaries, in which eligibility information was maintained. CAUSE: It appears that the filing system used by the Council for tracking the check-out and return to the filing room of the program beneficiaries? intake and eligibility documentation folders, may need to be improved upon. In addition, the Council has had recent personnel turnover and has also moved folders from one storage location to another. EFFECT: Certain beneficiaries? folders were not provided on demand to demonstrate beneficiaries? eligibility to participate in the program, leading to non-compliance with the programs? requirement for proper documentations of eligibility determinations. RECOMMENDATION: The Council should review and improve the system of tracking the checkout and return of beneficiaries? folders, to avoid their misplacements or loss.
Show full finding ▾Hide full finding ▴AUDIT FINDING REFERENCE No. 2021?002: Federal Department: U.S. Department of Health and Human Services Program Name: Community Services Block Grant (CSBG) Assistance Listing No. 93.569 Program Name: Low-Income Home Energy Assistance Program - Operated as Comprehensive Energy Assistance Program (CEAP) Assistance Listing No. 93.568 Compliance Requirement: Eligibility Documentations CRITERIA: LIHEAP and CSBG statutes establish client eligibility criteria as well as requirements to verify clients? income as part of the eligibility criteria. Accordingly, federal regulations require the Council to maintain records sufficient to document client eligibility and need for receiving benefits under these program. CONDITION: CSBG - Out of 25 unduplicated samples of program beneficiaries, the Council was unable to produce the folders maintained for 2 beneficiaries, in which eligibility information was maintained. LIHEAP ? Out of 25 unduplicated samples of program beneficiaries, the Council was unable to produce the folders maintained for 3 beneficiaries, in which eligibility information was maintained. CAUSE: It appears that the filing system used by the Council for tracking the check-out and return to the filing room of the program beneficiaries? intake and eligibility documentation folders, may need to be improved upon. In addition, the Council has had recent personnel turnover and has also moved folders from one storage location to another. EFFECT: Certain beneficiaries? folders were not provided on demand to demonstrate beneficiaries? eligibility to participate in the program, leading to non-compliance with the programs? requirement for proper documentations of eligibility determinations. RECOMMENDATION: The Council should review and improve the system of tracking the checkout and return of beneficiaries? folders, to avoid their misplacements or loss.
The agency agrees with this finding. In November 2021, the Director of Neighborhood Services (Dr. Sonia K. Boone) initiated a checks and balances system that presently includes the participation of the Team Lead (Ms. Lucille McGaskey), the Project Manager (Mrs. Priscilla Brown-Merritte), and all case managers. The project manager has the responsibility of reviewing client folders upon initial intake to ensure that all documentation from the client is complete and correct prior to remanding said folder to the team lead. The team lead has the responsibility of assigning client folders to case managers and the maintenance of a log that describes when folders are assigned, to whom, and when completed folders are remanded back to the team lead. Once completed folders are remanded back to the team lead, the team lead then reviews the client folder to ensure that all documentation is complete and correct. The team lead then remands the client folder back to the project manager, who files the folder, and notates in a log. This process is ongoing.
FAC accepted this audit on February 15, 2022 — management decision was due August 15, 2022.
AUDIT FINDING REFERENCE No. 2020?001: Federal Department: U.S. Department of Health and Human Services Program Name: Low-Income Home Energy Assistance Program - Operated as Comprehensive Energy Assistance Program (CEAP) CFDA No. 93.568 Compliance Requirement: Matching, Level of Effort, Earmarking CRITERIA: The Council?s CEAP program contract delineated the program?s total budget for the year into three main expense categories comprising (1) direct services to clients, (2) program services expenses, and (3) program administration expenses. The contract required the Council to incur program services expenses and program administration expenses in certain limited proportions to the direct services to clients expenses. CONDITION: During the fiscal year ended November 30, 2020, the Council exceeded the allowable proportionate share of the CEAP program?s budget for program services expenses and program administration expenses. To pay for these extra expenses, the Council drew-down on the program?s budgets earmarked for program services expenses and program administration expenses at a far greater rate than the amount the Council had earned relative to direct services to clients. For the fiscal year ended November 30, 2020, a total of $510,583 of expenses charged to the CEAP program did not meet the above described criteria for earning the federal award revenue. CAUSE: During the COVID-19 pandemic restrictions on person-to-person contacts in 2020, the Council could not achieve program outreach and client in-take targets and was unable to earn sufficient program revenues to offset its operational expenses. EFFECT: Certain CEAP program expenses have been reported as refundable program advances in the Council?s fiscal year 2020 financial statements. RECOMMENDATION: The Council should establish processes and controls to ensure timely suspension or termination of programs that are not generating sufficient revenues to cover the operational costs that are attributed to those programs.
Show full finding ▾Hide full finding ▴AUDIT FINDING REFERENCE No. 2020?001: Federal Department: U.S. Department of Health and Human Services Program Name: Low-Income Home Energy Assistance Program - Operated as Comprehensive Energy Assistance Program (CEAP) CFDA No. 93.568 Compliance Requirement: Matching, Level of Effort, Earmarking CRITERIA: The Council?s CEAP program contract delineated the program?s total budget for the year into three main expense categories comprising (1) direct services to clients, (2) program services expenses, and (3) program administration expenses. The contract required the Council to incur program services expenses and program administration expenses in certain limited proportions to the direct services to clients expenses. CONDITION: During the fiscal year ended November 30, 2020, the Council exceeded the allowable proportionate share of the CEAP program?s budget for program services expenses and program administration expenses. To pay for these extra expenses, the Council drew-down on the program?s budgets earmarked for program services expenses and program administration expenses at a far greater rate than the amount the Council had earned relative to direct services to clients. For the fiscal year ended November 30, 2020, a total of $510,583 of expenses charged to the CEAP program did not meet the above described criteria for earning the federal award revenue. CAUSE: During the COVID-19 pandemic restrictions on person-to-person contacts in 2020, the Council could not achieve program outreach and client in-take targets and was unable to earn sufficient program revenues to offset its operational expenses. EFFECT: Certain CEAP program expenses have been reported as refundable program advances in the Council?s fiscal year 2020 financial statements. RECOMMENDATION: The Council should establish processes and controls to ensure timely suspension or termination of programs that are not generating sufficient revenues to cover the operational costs that are attributed to those programs.
VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS: The Council made various efforts in 2020 to increase the total amount of direct assistance to clients by implementing suitable delivery models, staff training, and outreach despite the challenges posed by the Covid-19 pandemic. The Council was targeting to further increase the direct assistance to clients significantly in 2021 and be able to generate more earnings through this targeted increment in the number program beneficiaries and also through greater program delivery efficiency, in order to recover the excess administration and program services costs incurred in 2020. However, the Council was not awarded the CEAP 2021 contract or any other flexibilities by the funding agency, and all active CEAP contracts with the state agency were terminated. Accordingly, the Council stopped all CEAP program operations in May 2021. No further action is required by the Council.
AUDIT FINDING REFERENCE No. 2020?002: Federal Department: U.S. Department of Health and Human Services Program Name: Community Services Block Grant (CSBG) CFDA No. 93.569 Compliance Requirement: Special Tests and Provisions: Tri-Partite Board Structure CRITERIA: The CSBG Act and the Texas Administrative Code require, among others, that one-third of the members of the board shall be elected public officials, holding office on the date of the selection, or their designee; and one-third are members from the private sector. Another one-third shall be from the low-income communities served. The regulations also require that in no event shall the Board allow 25% or more of either the public, private, or low-income sector Board positions to remain vacant for more than 90 days. CONDITION: We noted that one (1) vacancy existed in the public sector while two (2) vacancies existed in the private sector, based on the 12-member Board structure of the Council. CAUSE: It appears that it has been hard to find people in the constituencies served by the Council, who are willing to serve on the Board. It also appears that the difficulty is increased by the fact that the Board must be composed in a tri-partite way that has minimum representations for the different segments (public sector, private sector, and low income groups.) EFFECT: The vacancies represented a 25% and a 50% negative impact for the public and private sectors? representations, respectively. RECOMMENDATION: The Council needs to ensure that its tri-partite Board structure complies with the CSBG Act and the Texas Administrative Code requirements.
Show full finding ▾Hide full finding ▴AUDIT FINDING REFERENCE No. 2020?002: Federal Department: U.S. Department of Health and Human Services Program Name: Community Services Block Grant (CSBG) CFDA No. 93.569 Compliance Requirement: Special Tests and Provisions: Tri-Partite Board Structure CRITERIA: The CSBG Act and the Texas Administrative Code require, among others, that one-third of the members of the board shall be elected public officials, holding office on the date of the selection, or their designee; and one-third are members from the private sector. Another one-third shall be from the low-income communities served. The regulations also require that in no event shall the Board allow 25% or more of either the public, private, or low-income sector Board positions to remain vacant for more than 90 days. CONDITION: We noted that one (1) vacancy existed in the public sector while two (2) vacancies existed in the private sector, based on the 12-member Board structure of the Council. CAUSE: It appears that it has been hard to find people in the constituencies served by the Council, who are willing to serve on the Board. It also appears that the difficulty is increased by the fact that the Board must be composed in a tri-partite way that has minimum representations for the different segments (public sector, private sector, and low income groups.) EFFECT: The vacancies represented a 25% and a 50% negative impact for the public and private sectors? representations, respectively. RECOMMENDATION: The Council needs to ensure that its tri-partite Board structure complies with the CSBG Act and the Texas Administrative Code requirements.
VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS: All board vacancies have been filled as of December 31, 2021.
FAC accepted this audit on October 14, 2020 — management decision was due April 14, 2021.
FAC accepted this audit on September 30, 2019 — management decision was due March 30, 2020.
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2017-003
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FAC accepted this audit on August 30, 2018 — management decision was due March 2, 2019.
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2016-001
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2016-004
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2016-003
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FAC accepted this audit on October 16, 2017 — management decision was due April 16, 2018.
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