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Southeast Arkansas Community Action Corporation Did Not Always Operate Its Head Start Program in Accordance With Federal Regulations

Issued on  | Posted on  | Report number: A-06-16-00015

Southeast Arkansas Community Action Corporation (Southeast) did not always operate its Head Start program in accordance with Federal regulations and did not always manage and account for Federal funds. Specifically, Southeast (1) had ineffective controls and accountability over its assets, (2) used questionable methods to allocate shared costs, (3) did not have required fiscal or legal expertise on its governing board, and (4) claimed some unallowable costs.

We recommended that Southeast (1) conduct a full physical inventory to ensure inventory asset records are accurate and complete, follow its existing purchasing policy to submit a purchase requisition one week in advance, and expand its purchasing policies to include review procedures for credit card purchases and consequences for unauthorized purchases; (2) work with the Office of Head Start to ensure shared costs claimed during our audit period are allocated correctly; (3) elect members to the board of directors who have legal and financial expertise or hire a consultant or another individual with relevant expertise; and (4) refund $4,784 in unallowable costs.

We also made other procedural recommendations.

In written comments on our draft report, Southeast concurred with all but one of our recommendations and provided information on actions it has taken or plans to take to address our recommendations. Southeast did not fully concur that $4,784 of costs are unallowable and should be refunded. Specifically, Southeast requested that $4,677 of these costs be reconsidered as allowable because Southeast believes it benefits the Head Start program. We maintain that these costs are unallowable because they do not benefit the Head Start program.

18-A-06-003.01 to ACF - Closed Implemented
Closed on 05/30/2018
We recommend that Southeast Arkansas Community Action Corporation conduct a full physical inventory to ensure that inventory asset records are accurate and complete, and update the inventory asset records as assets are purchased, moved, or disposed.

18-A-06-003.02 to ACF - Closed Acceptable Alternative
Closed on 03/28/2023
We recommend that Southeast Arkansas Community Action Corporation complete bank reconciliations in a timely manner, and properly segregate duties associated with bank reconciliations.

18-A-06-003.03 to ACF - Closed Implemented
Closed on 05/30/2018
We recommend that Southeast Arkansas Community Action Corporation limit future drawdowns from the Health and Human Services Payment Management System to past expenditures and immediate future needs as recorded in the general ledger.

18-A-06-003.04 to ACF - Closed Implemented
Closed on 05/31/2018
We recommend that Southeast Arkansas Community Action Corporation follow its existing purchasing policy to submit a purchase requisition 1 week in advance, as well as expand its purchasing policies to include (1) an individual assigned to review credit card purchases on a monthly basis and (2) a policy establishing consequences for employees who make unauthorized purchases.

18-A-06-003.05 to ACF - Closed Implemented
Closed on 05/31/2018
We recommend that Southeast Arkansas Community Action Corporation update its cost allocation plan to include only the methodology that allocates vacation, holiday, and sick pay based on the percentage of hours worked for each program.

18-A-06-003.06 to ACF - Closed Implemented
Closed on 05/31/2018
We recommend that Southeast Arkansas Community Action Corporation work with the Office Head Start to ensure that shared costs claimed during our audit period are allocated correctly, document its methodology for allocating shared costs, develop a written policy that explains how to perform cost allocations, and require a second level of  review for cost allocations to ensure the application of correct data to properly allocate costs.

18-A-06-003.07 to ACF - Closed Implemented
Closed on 05/31/2018
We recommend that Southeast Arkansas Community Action Corporation update its cost allocation plan to address how to allocate shared equipment costs to more than one program.

18-A-06-003.08 to ACF - Closed Implemented
Closed on 05/31/2018
We recommend that Southeast Arkansas Community Action Corporation elect members to the board of directors who have legal and financial expertise or retain the services of a consultant with relevant expertise.

18-A-06-003.09 to ACF - Closed Implemented
Closed on 05/31/2018
We recommend that Southeast Arkansas Community Action Corporation refund $4,784 in unallowable costs.

View in Recommendation Tracker