Not All Community Services Block Grant Recovery Act Costs Claimed on Behalf of the Community Action Partnership of Natrona County for the Period July 1, 2009, Through September 30, 2010, Were Allowable

Of the $854,000 in Community Services Block Grant (CSBG) Recovery Act funds that the Wyoming Department of Health (State agency) claimed on behalf of Community Action Partnership of Natrona County (Natrona County), $749,000 was allowable under the terms of the American Recovery and Reinvestment Act of 2009 (Recovery Act) and applicable Federal requirements. However, $105,000 in CSBG Recovery Act funds was not allowable under the terms of the grant and applicable Federal regulations. Specifically, Natrona County claimed $102,000 in CSBG Recovery Act funds that was unallowable because Natrona County and its subcontractors distributed these funds to recipients without adequately supporting their eligibility determinations. Additionally, contrary to U.S. Department of Health and Human Services, Administration for Children and Families (ACF), guidelines, Natrona County expended $3,000 for rental assistance after the Recovery Act funding period had ended.

Natrona County and its subcontractors did not have written policies and procedures to ensure that the subcontractors collected and maintained documentation to support their recipient eligibility determinations. In addition, Natrona County did not have written policies and procedures to ensure that it expended CSBG Recovery Act funds before the end of the funding period. As a result, the State agency overstated its claim to the CSBG Recovery Act grant by a total of $105,000.

In addition, we noted internal control weaknesses related to Natrona County's monitoring of subcontractors, segregation of duties, check authorizations, and uninsured bank accounts. Natrona County's lack of policies and procedures regarding eligibility determinations and internal control weaknesses related to the monitoring and safeguarding of assets did not ensure that Natrona County conformed to the terms of the grant and applicable Federal requirements.

We recommend that the State agency (1) make a financial adjustment to ACF of $105,000 for costs claimed by Natrona County that did not conform to the terms of the Recovery Act grant and applicable Federal requirements, and (2) ensure that Natrona County either develops or implements policies, procedures, and related internal controls regarding eligibility determinations, funds management, and monitoring of the CSBG program. Natrona County and the State agency generally disagreed with our findings and recommendations.