Not All Community Services Block Grant Costs Claimed on Behalf of the Carbon County Community Action Committee for the Period October 1, 2008, Through September 30, 2010, Were Allowable

Of the $302,000 in Community Service Block Grant (CSBG) funds and CSBG Recovery Act funds that the Wyoming Department of Health (State agency) claimed on behalf of Carbon County Community Action Committee (Carbon County), $75,000 was allowable under the terms of the CSBG and CSBG Recovery Act grants and applicable Federal requirements. However, $144,000 in CSBG funds and CSBG Recovery Act funds was not allowable under the terms of the grants and applicable Federal regulations. Specifically, Carbon County claimed $142,000 in CSBG and CSBG Recovery Act funds that was unallowable because Carbon County's subcontractors distributed these funds to recipients without adequately supporting the subcontractors' eligibility determinations. Carbon County claimed an additional $2,000 in CSBG and CSBG Recovery Act funds that was unallowable due to a variety of errors, including duplication of claims, lack of documentation, and services that were claimed even though they had previously been funded under another funding source.

In addition, because our limited scope review identified unallowable costs to the extent summarized in the report, some of the other costs were potentially unallowable. Although we did not perform detailed testing of costs totaling $83,000, we are referring those costs to the U.S. Department of Health and Human Services, Administration for Children and Families (ACF), and the State agency for resolution.

Carbon County did not have written policies and procedures to ensure that its subcontractors collected and maintained documentation to support their recipient eligibility determinations. As a result, the State agency overstated its claim to the CSBG and CSBG Recovery Act grants by a total of $144,000. In addition, we noted internal control weaknesses related to Carbon County's monitoring of subcontractors, tracking of Recovery Act funds, participation by members at Board of Directors meetings, and bank deposits in excess of Federal Deposit Insurance Corporation limits.

We recommended that the State agency (1) make a financial adjustment to ACF of $144,000 for costs claimed by Carbon County that did not conform to the terms of the CSBG and CSBG Recovery Act grants and applicable Federal requirements, (2) work with ACF to determine whether the eligibility determinations associated with the $83,000 were correctly made and make a financial adjustment to ACF of any unallowable costs, and (3) ensure that Carbon County either establishes or strengthens policies, procedures, and related internal controls regarding eligibility determinations, documentation, funds management, and oversight and monitoring of the CSBG program. Carbon County and the State agency generally disagreed with our findings and recommendations.