By Joel Washburn
washburn@mckenziebanner.com |
MARTIN (June 12) No action was taken against the
Northwest Tennessee Head Start Director Pam Castleman
during a joint meeting of the Northwest Tennessee
Economic Development Council Board and the Head Start
Policy Council on the UT-Martin campus. The non-action
effectively ends any action by the local boards.
After an audit by Alexander Thompson and Arnold (ATA) of
Union City based on at least 24 current and former
employee complaints, the board decided that no criminal
action had occurred, while they did indicate stronger
oversight is needed by their related boards.
During the two-plus hour meeting, Mrs. Castleman
presented a PowerPoint presentation to the 31 board
members and approximately 60 associates and family
members in attendance. Castleman picked apart ATA’s
audit and in the end asked for ATA to apologize to her
and Head Start and to retract their report filled with
errors and inaccuracies.
Henry County Mayor Brent Greer said ATA should have
included management’s response in the initial report. He
said now, since ATA has management’s response, they
should respond by concurring or disputing management’s
response.
ATA said they would review the additional information
and modify the report as requested by the boards.
The following were the allegations against Castleman and
her associates. The allegations were filed by associates
of Head Start, which led to the Regional Head Start
Office in Atlanta to request the audit. Castleman said
the allegations were filed by disgruntled former
employees.
The following report contains allegations, ATA’s
findings, and comments by Castleman.
1.Allegation: Mrs. Pam Castleman purchased her
personal Suburban on the same day as a Suburban was
purchased for Head Start and may have received some
benefit personally for buying both vehicles.
Procedure Performed by ATA: A Carfax report was
obtained using the VIN# on the finance papers provided
by Mrs. Castleman. This report provided the title number
used for a title history obtained from the State of
Tennessee.
Finding by ATA: The Carfax report on the
Castlemans’ personal vehicle showed that the title was
originally registered with the State of Tennessee in
October 2003, over two months prior to the date given by
Mrs. Castleman. The title number from the State report
showed the Castlemans as the owners. No additional
information could be obtained from the car dealer
concerning the date of purchase without legal
proceedings. The loan paperwork provided on each of the
vehicles indicated the following: the Castlemans’
personal vehicle was financed at an interest rate of
4.60% for 72 months; the Head Start vehicle was financed
at an interest rate of 7.60% for 48 months.
Comments by Castleman: No specific determination
of the validity of the allegation is provided. Mrs.
Castleman provided ATA with the only document personally
available which was the Castleman’s loan document. ATA
used part of the information from this document to
provide the reader with the additional data concerning
the transaction.Information available but not included
in this report includes:
- The Head Start Suburban was leased not purchased.
- The loan papers the interest rates are taken from
are over 3.5 months apart.
The interest rate differences noted in the report might
have the affect of raising additional questions and
fueling suspicions since the facts listed above, which
impact interest rates, were not disclosed.
In addition, the loan documents listed the purchase
prices of both vehicles which ATA chose not to disclose.
- Head Start Vehicle $45,676.17
- Castleman Vehicle $47,666.00
ATA never informed Mrs. Castleman that they were denied
access to additional information. Castleman noted that
one former employee, Lora Wofford, rode with Castleman
in Castleman’s personal vehicle to take delivery of the
new Surburban for Head Start. Wofford then drove
Castleman’s vehicle back to McKenzie.
2. Allegation: Mrs. Castleman used her position
with Head Start to accept her son into the program
without following the proper procedures. Her son then
received dental work during that time at the expense of
the Head Start program.
Procedure Performed:The application process was
examined to determine if proper procedures had been
followed in the case of Mrs. Castleman’s son. A copy of
the waiting list was also reviewed. Cash disbursement
records were reviewed to determine the amount of dental
work received by her son during that time.
Finding: Mrs. Castleman accepted her son into the
program after the formal selection process had taken
place for that year. There were eligible children with
disabilities and within the income guidelines on the
waiting list at that time. Mrs. Castleman is above the
income guidelines used to determine eligibility for the
program. Within one month of her son’s registration,
there were $414 in dental bills paid by Head Start. We
were also informed by other employees that Mrs.
Castleman’s other son had been in the program and
received dental work during that time through Head
Start. The former center coordinator said that both
children attended regularly and that attendance was not
an issue.
Comments: No specific determination of the
validity of the allegation is provided but we feel the
average reader would comprehend the wording of the
findings to be in favor of the allegation. The following
questions should have been answered in determining the
accuracy of the allegation:
- Can the program serve children who are
over-income? YES
- Must the over-income children served have a
disability? NO
- Does the local program offer enrollment to
all staff children in Head Start? YES -
She noted that her two sons have been diagnosed with
disabilities and that 119 associates of Head Start have
had their children enrolled in the program.
- Must all children, including over income
children, be provided the full scope of services?
YES
- Was Mrs. Castleman’s child provided
services above and beyond other staff’s
children? NO
Acceptance Process: ATA made no attempt to gain
knowledge of relevant information concerning this
allegation. No staff members who would be in a position
to know were asked questions concerning this allegation.
ATA’s statement that Mrs. Castleman accepted her son into
the program after the formal selection process had taken
place for the year is not valid based on the following:
The words “formal selection process” are incorrectly
used to indicate an “event” rather than a process. There
is no such thing as a “formal selection” event.
Acceptance is on-going throughout the year.
It is assumed that ATA was referring to the first round
of selecting children which our program calls the “the
initial selection of children”. If this is indeed the
event to which they are referring, the answer is simple.
The instructions in the procedure stated that only
income eligible children were to be selected during the
initial selection event. As ATA states, Mrs. Castleman’s
child was not accepted until after the first round of
acceptance was performed.
It is the program’s opinion that ATA did not demonstrate
the validity of the allegation.
Mrs. Castleman did not use her position to accept her
child in the program nor did she use her position to
circumvent the procedure for accepting children.
3. Allegation: Flex time and the related overtime
created is not being handled properly by Head Start.
Procedure Performed: Time sheets were examined for
several periods of time to determine if flex time and
overtime were being handled properly. Center
coordinators were also interviewed to determine how they
were handling these items.
Finding: After discussions with several center
coordinators and HR employees, and the review of time
sheets for several months, it was determined that flex
time/overtime was not being handled properly. Staff
members were under the impression that Head Start would
not pay overtime even if earned. Federal labor laws
stipulate that all flex time must be used during the
forty hour work week. However, if employees are paid
bi-weekly, the overtime from the first forty-hour period
can be rolled to the second forty-hour period at the
rate of time and a half. If it is not used by the end of
the second forty-hour week, then it must be paid to the
employees at the rate of time and a half. Furthermore,
the US Department of Health and Human Services has more
stringent guidelines for Head Start. Their guidelines
state that all non-exempt employees may not be given
time off in lieu of paying overtime based on a 40-hour
week, unless the time off is taken in the same week.
Center coordinators are editing time cards to eliminate
the overtime accrued, as well as incorrectly applying
flex time at the rate of only one hour allowed for one
hour earned. Edits should not be made to time cards
unless there are extenuating circumstances; for example,
an employee was not able to clock out.
Comments:
ATA states they determined that flex time/overtime was
not being handled properly. At this time, the program
has not been provided with any information to
substantiate this statement.
However, several statements by ATA cause the program to
question the validity of this determination. The U.S.
Department of Health and Human Services does not have
any guidelines concerning overtime, and no statute cite
is provided for this regulation.
ATA also states that edits should not be made to time
cards unless there are extenuating circumstances. The
Federal Labor Law Regulations does not support this
statement. In regards to record keeping, the Federal
Labor regulations even state that an employer may
assign an employee the task of completing time records
for other employees. An employee is not personally
required to record his own time. The regulations do not
state that errors in time records cannot be edited.
With the information available at this time, the program
finds no facts to substantiate ATA’s statement that flex
time/overtime was not being handled properly. Castleman
demonstrated where one of the complainant employees
actually was paid more hours than she should have been
paid.
4. Allegation: There is excessive inappropriate mileage
paid to management staff and employees. Also, there are
Head Start vehicles provided to employees that do not
appear to have a need for a company vehicle.
Procedure Performed:
Mileage reimbursements were examined to determine the
amount of mileage reimbursed. There were also
discussions with staff and former staff regarding the
repayment of mileage.
Finding:
We (ATA) examined a central office employee’s mileage
reimbursement for the 2006 fiscal year. She was
reimbursed a total of $5,412 for mileage during the
fiscal year. During this time Head Start owned a
Suburban which the I.T. Administrator drove back and
forth from home to work. The mileage for the Suburban
was not reported on the I.T. Administrator’s W-2 as a
fringe benefit and the cost was also not reported as an
unallowable cost. In accordance with A-122, federal
guidelines state that mileage on company vehicles used
to transport employees to and from work, where this is
not required to perform job duties, is not an allowable
cost. This same situation applies to a Crown Victoria
that is driven by the Huntingdon center coordinator. It
appears to us that Head Start is paying for mileage
reimbursements instead of using vehicles it owns for
necessary travel needs.
Comments: ATA states that it “appears” to us that Head Start is
paying for mileage reimbursements instead of using
vehicles it owns for necessary travel.
This allegation was not discussed with staff members who
are in a position to know. No member of management was
asked to provide information on this topic.
Vital information that should have been a part of the
discovery included:
- Does the IT Administrator just drive from home to
work?
- Does the program have any information that shows how
many miles the IT Administrator traveled that did not
include home to work commute?
- Are there other factors besides miles driven that
need to be factored in?
ATA did not seek vital information for this allegation.
The statement “that it appears” is not supported by the
information provided. ATA does not show the validity of
the allegation that excessive, inappropriate mileage is
being paid. Furthermore, the report does not demonstrate
the validity of the allegation that Head Start vehicles
were provided to employees that do no need them.
5. Allegation: Head Start is paying for employees to
attend conferences and out-of-town training and the
employees are not attending the training sessions.
Procedure Performed:
We (ATA) discussed this issue with the national Head
Start office and employees and former employees of Head
Start.
Finding: Per discussions with the National Head Start
Association, there are no records on file that show
whether someone did or did not attend sessions of a
conference. However, records were examined for one
particular conference and no one had signed to indicate
they had picked up the conference packets. This is not a
requirement of the conference, but generally attendees
sign for the packets. We discussed the issue with several
former employees and they all stated that they had not
fully attended the conferences they traveled to. They
stated that they were told by their supervisors that
they did not have to attend the sessions. There were
also circumstances report where the former employees had
traveled with Mrs. Castleman and were told not to bother
go to the sessions.
Comments by Castleman: ATA was not able to determine
the validity of the allegation.
6. Allegation: Several allegations were made regarding
the Facilities Administrator Tracy Webb. The first
allegation was that he owned a company that sold
printers to Head Start. The second was that he used Head
Start employees for work on his personal property. The
third was that Head Start rents storage space from his
mother.
Procedure Performed: We (ATA) examined invoices and
talked to employees regarding the allegations made.
Finding: The Head Start purchased $8,633 worth of
printer supplies from WebbCo during fiscal year 2006. It
is our understanding that Head Start is no longer doing
business with WebbCo. Tracy Webb did use Head Start
employees at least one time to work on his personal
rental property. Head Start did rent space in Webb
Storage, which we (ATA) understand is owned by Tracy
Webb’s mother. The HDS Grants Administration Manual,
which expressly applies to discretionary grants such as
Head Start, states: “. . .no grantee agency employee,
officer, or agent shall participate in the selection,
award, or administration of a procurement contract
supported by Federal funds if a real or apparent
conflict of interest would be involved. Based on the
regulations, such conflict would arise when the
employee, officer, or agency, or any member of his or
her immediate family, his or her partner, or an
organization which employs or is about to employ any of
the parties indicated, has a financial or other interest
in the firm selected for an award”.
Comments by Castleman: ATA correctly quotes a
regulation, but the report does not provide a specific
determination on the validity of these allegations based
on this regulation.
Apply the regulation by asking:
- Did Mr. Webb
participate in the selection, award, or administration
of the contract? NO - The work on the rental property was
when the water heater burst at one of Webb’s mother’s
apartments immediately after Webb’s dad died. A couple
of the Head Start maintenance people delivered a wet vacuum to Webb at the apartment and offered to remove
the broken water heater. They did so while he was gone
to get a new heater. They also did so without his
knowledge. Mr. Webb said it took about one hour.
This negative answer ends the question of violating the
stated regulation.
7. Allegation: Mrs. Castleman has used family to perform
contracted work for Head Start.
Procedure Performed: We (ATA) examined invoices and
talked to employees regarding the allegations made.
Finding: There were various instances of nepotism noted
during the years tested with regards to numerous
employees, including Mrs. Castleman. The policy council
should adopt a policy regarding nepotism so that this
issue does not come up again in the future. The HDS
Grants Administration Manual, which expressly applies to
discretionary grants such as Head Start, states: “The
recipient’s personnel policies shall prohibit the hiring
of any individual if a member of that individual’s
immediate family is employed in an administrative
capacity in the agency or is a member of the governing
board. The term “immediate family” means wife, husband,
son, daughter, mother, father, brother, sister, or
relative by marriage of comparable degree; the term
“administrative capacity” means a position having
responsibilities relating to the selection, hiring or
supervising of employees. When a recipient organization
cannot adequately staff positions without hiring such an
individual, the recipient may deviate from this policy.
However, employment records must provide evidence that
no other individual within the service area is qualified
and available for the employment.”
Comments: The allegation in the report omits vital
information from the actual allegation. The actual
allegation stated the Mrs. Castleman has used her niece
and nephew to perform work for Head Start.
ATA states that there were various instances of nepotism
noted but does not provide any examples. At this time,
the program has not been provided any details to
substantiate this conclusion.
Also, ATA states that the policy council should adopt a
policy regarding nepotism. The program has a nepotism
policy. A review of the policy would be necessary to
determine if nepotism has indeed taken place.
Once again, ATA did not seek out the appropriate
information or review source documents prior to making a
determination that the allegation was valid. Castleman
presented a list of employees whose family or extended
family have worked for the center. Complainant Wofford’s
daughter, Brittany Lessenberry, was employed for a
period, said Castleman.
8. Allegation: The Central Office has been upgraded
significantly while centers have not received adequate
funding to provide services to children.
Procedure Performed: We (ATA) examined invoices and
talked to current and former center coordinators
regarding the allegations made.
Finding: The Central Office has been renovated
extensively since the Head Start program has moved its
operations back to that location (McKenzie- Webb
School). Center coordinators also informed us that their
offices had been renovated and new furniture purchased.
Furniture purchases were generally made to replace
desks, etc. that were still usable and held value. We
discussed with center coordinators the allegations
regarding inadequate funding and all of the current
center coordinators we interviewed said that the
children were receiving the things needed. They also
informed us that they have rarely had purchase orders
turned down by the Central Office. When former
coordinators were interviewed, they stated that they had
been turned down for items such as art supplies,
toothpaste, toothbrushes, clothing, etc. These items
were turned down between purchase cycles and the center
would make do with existing supplies. For example,
children would share tubes of toothpaste, even though
this was against Head Start policy.
Comments: No specific determination of the validity of
the allegation is listed.
The program would like to know how ATA came to the
conclusion that furniture purchases were generally made
to replace desks, etc. that were still useable and held
value.
9. Allegation: A 50-inch plasma television was purchased
for Mrs. Castleman’s office with a total cost of $4,500.
Procedure Performed: We (ATA) examined invoices for the
purchase, as well as discussed the issue with Mrs. Castleman.
Finding: There was a television purchased for a total
cost of approximately $4,500 that is in Mrs. Castleman’s
office. The governing body of the program should
determine that all expenses are “reasonable and
necessary” as required by 0MB Circular A-133 and
applicable cost circulars for the operation of the
program.
Comments by Castleman: ATA did not discuss the TV with
Mrs. Castleman as they state.
Following the limit of the conversation on this topic:
Mrs. Castleman asked, “Are you not going to ask me about
the television after so many people have made such an
issue of it?”
John B Whybrew said, “Well, it’s there and if I ask you
if you use it for training you will just tell me you
do.”
The program does not consider this conversation to
qualify as a discussion.
The program would like to note that Mrs. Castleman’s
office also includes a small group conference/training
area. The television is located in the area and is
connected to a PC and audio visual equipment. Castleman
showed a video of the room indicating the conference
table and chairs.
Since ATA did not attempt to validate the allegation,
the allegation should not have been included in the
report.
Also, ATA did not use available information to test the
reasonableness of the purchase.
10. Allegation: A presentation screen was purchased for
$1,659 and provided to the First Cumberland Presbyterian
Church in McKenzie, Tennessee, of which Mr. Webb is a
member.
Procedure Performed: We (ATA) examined contracts and
talked to Mrs. Castleman regarding the allegations made.
Finding: Head Start entered into an agreement with the
church to perform staff training at the church and in
return Head Start would provide a video screen to the
church. Since the agreement was signed, approximately
two years ago, Head Start has used the church for one
training session, which was held prior to the screen
being purchased. Training has subsequently been held in
Jackson, Dyersburg, etc. The governing body of the
program should determine that all expenditures are
“reasonable and necessary” as required by 0MB Circular
A-133 and applicable cost circulars for the operation of
the program.
Comments By Castleman: For unknown reasons, ATA has
chosen not to include the information on the screen that
was provided to them by the director, Pam Castleman.
The 05-06 annual pre-service training was scheduled to
take place at the University at Martin. Pre-service is
the only time during the year that the program can
provide large group training sessions to all 350
employees.
At approximately 7:00 p.m. the night prior to the event,
the University of Tennessee at Martin called the program
to inform us that they had had an asbestos accident, the
entire facility had to be closed, and that we would be
unable to use the building the next day. They also
informed us that all of their audio visual equipment
which we had planned to use was in the building and
could not be removed.
This was a scheduled staff administrative day and to
postpone the training to a later date would have cost
the program a full day payroll which would cost over
$27,000.
Due to the time of night we had to quickly decide what
to do and how to do it. We contacted the Garden Plaza
hotel, Jackson State Community College, Union
University, and Bethel College in the attempt to locate
an alternative space. None were available on that short
of notice and some did not have facilities capable of
housing the numbers.
We were finally able to obtain permission from the
Presbyterian Church to use their Family Life Center. The
church officials, along with Head Start staff, spent
many late hours into the night preparing for our early
morning arrival. In payment for allowing us to use their
facility, Head Start agreed to purchase the screen.
Management saw this as a better option than a one time
rent payment. The screen is there and we have a
partnership agreement that states we can use the
facility in the future if the need arises.
Again, ATA was provided this information, but chose not
to include it in the report. It would have been
appropriate to test the following:
- Is one day of payroll more than the cost of the
screen?
- Is the screen actually in the facility we state it is
in?
- Did the program use the church as stated?
- What would the typical rental fee be for the use of a
facility that size?
- Was there truly an asbestos accident on the day
pre-service was scheduled?
11. Allegation: Head Start disposes of property by
donating items to individuals as Mrs. Castleman chooses.
Procedure Performed: We talked to employees and former
employees regarding this allegation.
Finding: Head Start does seem to be replacing and giving
away property that appears to be in good condition,
including office furniture, classroom furniture, etc.
This is done by various means, including letting staff
have their choice of items, community “give-away days”
at the storage units, and auctions. The policy council
should establish a policy for handling out-of-service
furniture and fixtures. There is an appearance of
impropriety that could be corrected with an observed
policy in place. Guidelines should also be implemented
to control the replacement of furniture and fixtures, so
that these items are not replaced excessively or
unnecessarily. The governing body of the program should
determine that all expenditures are “reasonable and
necessary” as required by OMB Circular A-133 and
applicable cost circulars for the operation of the
program.
Comments by Castleman: ATA states that the program “does
seem” to be replacing and giving away property that
appears to be in good condition. ATA does not provide
any information as to what lead them to come make this
subjective conclusion. This information needs to be
provided immediately.
ATA states that a policy should be established for
handling out-of- service furniture and fixtures. The
program has a policy and the policy is followed. Source
documents were not reviewed.
Again, ATA did not ask any member of management if such
a policy already existed.
12. Allegation: There have been several issues raised
regarding the grievance process. These issues were
brought up in the initial allegations, as well as during
employee interviews.
Procedure Performed: We (ATA) talked to employees and
former employees regarding the grievance process. We
also examined employee files for documentation regarding
grievances filed.
Finding: We (ATA) recommend that the grievance process
be restructured so that there is someone in the EDC
presiding over the process that is independent of Head
Start. The personnel committee should act independently
of the program director to ensure that all parties
involved receive a fair hearing. Employees have the
perception that the grievance process is one-sided and
they do not receive fair and independent treatment.
Comments: ATA never interviewed any member of the
personnel committee nor a
member of management prior to making a recommendation.
It is obvious that ATA did not have an understanding of
the grievance process when they recommend that the
personnel committee act independently of the program
director or it would have discovered that it does do
exactly that. The program director does not, in any way,
direct these meetings. The policy council chairman
directs the meeting and the members of the personnel
committee decide what the correct course of action will
be. This course of action is then taken to the full
policy council for approval.
Since ATA did not ask management questions on this
topic, they have made recommendations that violate the
Head Start Performance Standards.
13. Allegation: Employees are not paid fairly and
equally for similar job titles across the program.
Procedure Performed: We (ATA) examined payroll records
documenting pay rates, as well as documented raises.
Finding: We noted on the pay rate roster that at times
there were employees that held the same position, had
been hired at similar times, and had different rates of
pay. We examined the payroll files and the explanation
provided was that the employees started with Head Start
in different positions. After several years the lower
ranked employee was promoted up to an equal position,
and their pay rate was determined by the base pay level
for that job, not their seniority. We recommend that the
personnel committee review promotions and raises and
that the policies applied be consistent with those of
the EDC.
Comment by Castleman: Again, it is unclear on ATA’s
determination of this allegation. The program would like
to note that there is a standard method for determining
pay rates and seniority is taken into account. Also, the
education level of the employee plays a major role in
determining salaries. Salaries are not arbitrarily
assigned.
A complete wage comparability study is conducted every
three years and comparisons for individual job titles
are done more often if needed.
14. Allegation: Unethical and improper methods are used
to terminate employees.
Procedure Performed: We discussed the issue with Mrs. Castleman, current employees and former employees.
Finding: All hiring and firing decisions should be
approved by the personnel committee, which should be
appointed independently of the program. The personnel committee should meet at least monthly to approve the
actions of the director. Meeting on an irregular or
infrequent basis indicates that the personnel committee
is not exercising its oversight duties on personnel
issues.
Comment: Again, it is clear that ATA did not have an
understanding of the Head Start Performance Standards in
reference to program governance. It is also clear that
they did not ask members of management or the policy
council any questions concerning the termination
process.
Points to make concerning the recommendation:
- The Policy Council must approve the actions of the
program director concerning hiring and firing.
- The Policy Council does approve all hiring and firing
actions.
15. Allegation: USDA records were falsified to receive
the maximum allowable benefit.
Procedure Performed:
We examined USDA reimbursements and Head Start records,
and discussed the allegation with Linda Brinkley.
Finding by ATA: Head Start used additional food service
salaries to apply for reimbursement. These salaries
should not have been reimbursed at the rate of 100%
because the salaries could not be fully claimed.
However, Head Start had employee benefits available that
could have been pulled into the reimbursement request,
which would offset the erroneous salaries. This would
have resulted in no change to the reimbursement.
Comment by Castleman: ATA states that Head Start used
additional food service salaries to apply for
reimbursement. (The allegation was for the May 2006 USDA
claim)
ATA did not review any USDA reimbursement documentation
nor does it appear that they reviewed the USDA
regulations. They did interview the finance officer who
felt ATA had an understanding of what she stated.
If source documents had been reviewed the allegation
would have been easily found to have no validity. Head
Start did not use food service salaries to “apply” for
reimbursement. No salaries, erroneous or not, were
reported on a claim.
16. Allegation: Wal-Mart gift cards were obtained and
not disbursed to the agencies as documented on the
purchase orders.
Procedure Performed: We examined the purchase orders as
well as talked to center coordinators.
Finding: Center coordinators did remember receiving
Wal-Mart gift cards around the time period noted on Mrs. Castleman’s response. Due to the fact that a significant
period of time has passed in some instances, there is no
way to determine whether exactly 186 gift cards were
disbursed.
Comment: The program has already put in place a
procedure requiring that staff receiving a gift card to
sign a statement to that affect.
17. Allegation: A 16-foot utility trailer that is owned
by Head Start is maintained at Mrs. Castleman’s
residence and is not always available for use.
Procedure Performed: We (ATA) talked to several former
employees and Mrs. Castleman regarding this matter.
Finding:
It is our understanding from discussions with a former
maintenance person that Head Start purchased a 16-foot
wire mesh bottom trailer several years ago. This trailer
was kept at the former maintenance person’s home and was
picked up from him when he ended his employment. The
trailer at Mrs. Castleman’s house is a 16-foot wood
floor trailer that Mrs. Castleman states belongs to her
husband. There is a 10-foot wire mesh bottom trailer
that is owned by Head Start and she believes that
trailer to be the one noted above.
Comment: As stated to ATA, the program does not and has
never owned a 16-foot utility trailer. However, the
program does owned a 12-foot wire mesh lawn mower
trailer. We believe this trailer was bought in the late
80’s and was used to haul a lawn mower between
facilities. ATA was shown a current picture of each
trailer. They asked Mrs. Castleman if she could prove
that the 16-foot wooden bottom, angle iron trailer
belonged to her. She produced an original picture that
was dated by the camera showing the trailer parked in
her yard in 1998. This is prior to Ms. Castleman’s hire
date.
The trailer had to be stored at someone’s home for the
lack of a secured place to park it at the office. As
stated by the former maintenance person this trailer was
stored at his house prior to him retiring. Neither
employee asked for compensation for agreement of
storage.
Due to the fact that the Head Start trailer is not large
enough nor appropriately built to haul certain items, the
facility department has used the Castleman’s trailer
numerous times at no cost to the program. Management had
discussed selling the trailer numerous times. (Mr.
Castleman was complaining of having to mow around it.)
The trailer was sold at auction and should no longer be
an issue. The proceeds were appropriately recorded as
program income. Head Start will now rent a trailer when
one is needed.
18. Allegation: Head Start maintains cellular phones for
staff that have no need for a program-provided cellular
phone.
Procedure Performed: No testing was done regarding this
issue.
Finding by ATA: From the file that Mrs. Castleman
provided in response to the original allegations, it was
noted that Head Start had 53 cellular phones as part of
its contract. We (ATA) have no way of determining
whether this is excessive in relation to the program.
The Board should evaluate job descriptors to determine
how many cellular phones are necessary to operate the
program.
Comment by Castleman: The program is unsure as to why
ATA reported on this topic since it was not tested.
Although ATA states that this was not tested, partial
data is provided and a recommendation is made.
ATA was provided the following data: There are 53
cellular phones and 19 of those are assigned to buses.
The program has a government contract that provides a
pool of 23,850 minutes for the use by all phones. The
contract also has free night and weekends. The
mobile-to-mobile that does not deduct from the allowable
minutes is a great advantage for the program since
centers are spread over 13 counties and operates in two
different area codes. This contract reduces the cost of
equipment (phones, chargers, etc) greatly.
19. Allegation: Head Start lays off employees to keep
from paying paid time off when schools are closed.
Procedure Performed: We (ATA) discussed the issue with
Mrs. Castleman.
Finding: Mrs. Castleman’s response was that the program
is funded for 160 days. When planning time off for
school closures, etc. she would try to schedule full
weeks off so that the employees could be laid off during
that time to collect unemployment. Paid time off must be
used during the 160 funded days, which only include the
days the centers are open. The funded days do not
include the days that staff is laid off.
Comment: No specific determination has been stated.
Although the data is somewhat different from what was
actually explained, it is close enough to not change the
general meaning.
20. Additional Allegation: A former employee alleged
that she was directed to falsify in-kind reports so that
the program would show enough in-kind contribution
revenue.
Procedure Performed: In-kind reports and child
applications were compared for similar signatures.
Finding by ATA: In our limited scope of testing we noted
an instance where the signature on an in-kind sheet did
not appear to match the signature on the child’s
application. Due to the fact that we are not handwriting
experts, we did not do any additional work. We believe
that if the Board wants to look further into this
matter, then someone with handwriting analysis expertise
should be asked to make further examinations. We did
discuss this issue with center coordinators and they
stated that they do not submit in-kind sheets without a
parent signature.
Comment by Castleman: ATA requested all in-kind
documentation for the three years of 03-04, 04-05, and
05-06. Out of the large quantity requested, ATA does not
state the number of in-kind records reviewed. They state
they noted a single instance where the signature on an
in-kind sheet did not appear to match the signature on
the application. Since the program was not provided with
any details as to which in-kind sheet was in question,
and in which center this former employee worked, the
program cannot respond other than stating these facts:
- In-kind forms are completed by the center staff.
- The program always has ample in-kind each year.
- If an employee was told to falsify documents, he/she
should have refused.
21. Additional Allegation: Purchase orders are being
approved after the purchases are made by Head Start
employees. In addition, bid procedures are not being
applied in accordance with state and federal
regulations.
Procedure Performed: We (ATA) examined invoices and
purchase orders and compared the dates on the two items.
We also looked at purchases over the bid threshold.
Finding: We (ATA) did note instances where purchase
orders and invoices were dated on the same day. In our
experience this generally signifies that items are
purchased prior to the approval. We recommend that the
Board adopt policies that are consistent for the entire
entity which includes Head Start and the EDC. The more
stringent individual policy items should be adopted
(state policy versus federal Head Start policy). We
would also recommend that these policies include
identical bid procedures and limits. State policies
require like items to be bid if the total purchase is
above the bid threshold. Like items are considered to be
items that are similar or are of similar use, such as
six different styles of desks.
Comments by Castleman: ATA makes a statement, although
not directly related to the allegation, that when
purchase orders are signed on the same date as the
purchase, it is their experience that this generally
signifies that items are purchased prior to approval.
The program is of the opinion that this observation is
inappropriate and appears to be made just to make a
statement since obviously they did not find any proof
that the actual allegation was valid.
If asked, management would have explained that there are
numerous examples as to why a purchase order approval
date is the same as the purchase date.
- The purchase order was for someone in the central
office that has quick access to approving officials.
- The purchase request was faxed in from the center to
obtain an immediate signature and then faxed back so the
purchase could be made that day.
- Modern means of purchasing are used in numerous
instances such as on-line ordering that produces a
receipt the same day the item is ordered.
Additional Allegation: The EDC is not exercising
adequate oversight over the Head Start Program and
director to justify the administrative costs that the
EDC charges to Head Start totaling approximately $30,000
per month.
Procedure Performed: We discussed these issues with the
Regional Head Start staff and other Head Start
personnel, as well as documented the controls currently
in place.
Finding: It appears as though Head Start and its
director operate somewhat autonomously of the EDC. EDC
personnel should be reviewing and approving Head Start
activity and approving all activity of the director. We
also believe that the HR function as well as the
accounting function should be overseen or monitored by
someone in the EDC office. Journal entries for the
month, monthly reports, budget to actual reports, etc.
should be monitored closely by someone at the EDC
office. It is our opinion that the EDC must improve and
enforce controls over Head Start in order to justify the
amount of administrative costs charged to the Head Start
program.
Comment: This issue should and will be reviewed to
determine what additional duties of EDC staff are
appropriate. However, the report makes it sound as if no
one supervises the Head Start director and therefore
there is no oversight of program activities. The
executive director supervises this position and does
request additional information as required to monitor
program operations.
23. Additional Allegation: Turnover for this particular
Head Start is higher than normal.
Procedure Performed: We pulled payroll records showing
employee turnover from July 1, 2004 through May 21,
2007.
Finding: During the period of time tested, 47 employees
were terminated, 90 employees resigned, 32 employees
quit, and four employees retired. As of May 1, 2007
there were 367 employees with Head Start, which amounted
to an estimated turnover rate of about 16% for the
period tested.
Comment: Termination figures are incorrectly stated. If
asked, management staff would have explained that the
word “termination” on the report does not mean “fired”.
The program is extremely pleased with the turn-over rate
of 16% for the past three years. This is a large
improvement over the 2000 rate of over 40%.
24. Additional Allegation: A bank account was maintained
by centers in Paris which was not recorded on Head
Start’s or the EDC’s books.
Procedure Performed: We discussed this with a former
center employee.
Finding: There was an account in Paris that was set up
to record deposits from a local organization that
donated money every year to be used for specified
purposes. This account was maintained by the center and
was not recorded on Head Start’s books. The former
employee indicated that a Program Manager was aware of
the account and never informed the employee that it
should be turned over. The former employee stated that
when Mrs. Castleman discovered there was an account, she
informed the employee that the money should be turned
over to the central office and disbursed from there.
Comments by Castleman: Management ordered these center
bank accounts to be closed over seven years ago.
Management had no knowledge that the account was still
open. The monies were derived from donations and were
donated to provide emergency crises funds for Head Start
parents. No disciplinary action was issued due to the
account still existing because management felt center
staff truly did not realize the accounts had been
ordered closed. However, diplomacy action was issued
when it was reported that the staff were being allowed
to borrow money from the account when they so desired and
then allowed to pay the money back as personal funds
permitted. All money owed was returned immediately and
the account was closed. According to CFR part 74, all
money donated or earned must be reported in the
financial books. This was performed. |
