Audit 14285

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561 and 10331 Pass-through Agency: The Pennsylvania State University and National Institute of Food and Agriculture Pass-through Number: S001650-COP-TFT; 2019-70030-30412; 2020-70030-33186; 2021-70034-34987; 2021-70034-35361 Award Period: October 1, 2021 - September 30, 2022; September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023; June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to accurately record and report fringe benefits based on the actual expenses incurred by the organization and to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained and reviewed to support all transactions. Condition: During our testing, we noted the Organization charges benefits to the programs based on an allocation calculated at 25% of salaries, but the actual benefits incurred are 20% of total salaries, there is a discrepancy between the allocated amount and the actual amount. We also noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $266 charged to the federal programs. Questioned Costs: The Organization allocated fringe benefits to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program more than the amount actually incurred by $99,699. The organization allocated fringe benefits to the Food Insecurity Nutrition Incentive Grants Program more than the amount actually incurred by $6,558.Context: During the review of the fringe benefits charged to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and the Food Insecurity Nutrition Incentive Grants Program, it was noted the amounts allocated for fringe benefits were in excess of the fringe incurred by the organization by $99,699 and $6,558, respectively. it was also noted management was unable to locate the supporting documentation for two transactions totaling $266. Cause: The Organization allocated fringe to the program based on the percentages included in the contract budget, as opposed to charging actual expenditures incurred to the grants. Management's internal controls did not prevent or detect the grants from being overcharged fringe benefits. In addition, the organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: Allocated costs that are not appropriately budgeted and invoiced could result in inaccurate reporting and misrepresentation of the program's expenses. If the organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust review the allocation process for fringe benefits to ensure amounts reflect a more accurate representation of the actual fringe benefits incurred by the Organization. In addition, the Food Trust should review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561 and 10331 Pass-through Agency: The Pennsylvania State University and National Institute of Food and Agriculture Pass-through Number: S001650-COP-TFT; 2019-70030-30412; 2020-70030-33186; 2021-70034-34987; 2021-70034-35361 Award Period: October 1, 2021 - September 30, 2022; September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023; June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to accurately record and report fringe benefits based on the actual expenses incurred by the organization and to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained and reviewed to support all transactions. Condition: During our testing, we noted the Organization charges benefits to the programs based on an allocation calculated at 25% of salaries, but the actual benefits incurred are 20% of total salaries, there is a discrepancy between the allocated amount and the actual amount. We also noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $266 charged to the federal programs. Questioned Costs: The Organization allocated fringe benefits to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program more than the amount actually incurred by $99,699. The organization allocated fringe benefits to the Food Insecurity Nutrition Incentive Grants Program more than the amount actually incurred by $6,558.Context: During the review of the fringe benefits charged to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and the Food Insecurity Nutrition Incentive Grants Program, it was noted the amounts allocated for fringe benefits were in excess of the fringe incurred by the organization by $99,699 and $6,558, respectively. it was also noted management was unable to locate the supporting documentation for two transactions totaling $266. Cause: The Organization allocated fringe to the program based on the percentages included in the contract budget, as opposed to charging actual expenditures incurred to the grants. Management's internal controls did not prevent or detect the grants from being overcharged fringe benefits. In addition, the organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: Allocated costs that are not appropriately budgeted and invoiced could result in inaccurate reporting and misrepresentation of the program's expenses. If the organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust review the allocation process for fringe benefits to ensure amounts reflect a more accurate representation of the actual fringe benefits incurred by the Organization. In addition, the Food Trust should review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561 and 10331 Pass-through Agency: The Pennsylvania State University and National Institute of Food and Agriculture Pass-through Number: S001650-COP-TFT; 2019-70030-30412; 2020-70030-33186; 2021-70034-34987; 2021-70034-35361 Award Period: October 1, 2021 - September 30, 2022; September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023; June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to accurately record and report fringe benefits based on the actual expenses incurred by the organization and to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained and reviewed to support all transactions. Condition: During our testing, we noted the Organization charges benefits to the programs based on an allocation calculated at 25% of salaries, but the actual benefits incurred are 20% of total salaries, there is a discrepancy between the allocated amount and the actual amount. We also noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $266 charged to the federal programs. Questioned Costs: The Organization allocated fringe benefits to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program more than the amount actually incurred by $99,699. The organization allocated fringe benefits to the Food Insecurity Nutrition Incentive Grants Program more than the amount actually incurred by $6,558.Context: During the review of the fringe benefits charged to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and the Food Insecurity Nutrition Incentive Grants Program, it was noted the amounts allocated for fringe benefits were in excess of the fringe incurred by the organization by $99,699 and $6,558, respectively. it was also noted management was unable to locate the supporting documentation for two transactions totaling $266. Cause: The Organization allocated fringe to the program based on the percentages included in the contract budget, as opposed to charging actual expenditures incurred to the grants. Management's internal controls did not prevent or detect the grants from being overcharged fringe benefits. In addition, the organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: Allocated costs that are not appropriately budgeted and invoiced could result in inaccurate reporting and misrepresentation of the program's expenses. If the organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust review the allocation process for fringe benefits to ensure amounts reflect a more accurate representation of the actual fringe benefits incurred by the Organization. In addition, the Food Trust should review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561 and 10331 Pass-through Agency: The Pennsylvania State University and National Institute of Food and Agriculture Pass-through Number: S001650-COP-TFT; 2019-70030-30412; 2020-70030-33186; 2021-70034-34987; 2021-70034-35361 Award Period: October 1, 2021 - September 30, 2022; September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023; June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to accurately record and report fringe benefits based on the actual expenses incurred by the organization and to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained and reviewed to support all transactions. Condition: During our testing, we noted the Organization charges benefits to the programs based on an allocation calculated at 25% of salaries, but the actual benefits incurred are 20% of total salaries, there is a discrepancy between the allocated amount and the actual amount. We also noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $266 charged to the federal programs. Questioned Costs: The Organization allocated fringe benefits to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program more than the amount actually incurred by $99,699. The organization allocated fringe benefits to the Food Insecurity Nutrition Incentive Grants Program more than the amount actually incurred by $6,558.Context: During the review of the fringe benefits charged to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and the Food Insecurity Nutrition Incentive Grants Program, it was noted the amounts allocated for fringe benefits were in excess of the fringe incurred by the organization by $99,699 and $6,558, respectively. it was also noted management was unable to locate the supporting documentation for two transactions totaling $266. Cause: The Organization allocated fringe to the program based on the percentages included in the contract budget, as opposed to charging actual expenditures incurred to the grants. Management's internal controls did not prevent or detect the grants from being overcharged fringe benefits. In addition, the organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: Allocated costs that are not appropriately budgeted and invoiced could result in inaccurate reporting and misrepresentation of the program's expenses. If the organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust review the allocation process for fringe benefits to ensure amounts reflect a more accurate representation of the actual fringe benefits incurred by the Organization. In addition, the Food Trust should review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561 and 10331 Pass-through Agency: The Pennsylvania State University and National Institute of Food and Agriculture Pass-through Number: S001650-COP-TFT; 2019-70030-30412; 2020-70030-33186; 2021-70034-34987; 2021-70034-35361 Award Period: October 1, 2021 - September 30, 2022; September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023; June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to accurately record and report fringe benefits based on the actual expenses incurred by the organization and to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained and reviewed to support all transactions. Condition: During our testing, we noted the Organization charges benefits to the programs based on an allocation calculated at 25% of salaries, but the actual benefits incurred are 20% of total salaries, there is a discrepancy between the allocated amount and the actual amount. We also noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $266 charged to the federal programs. Questioned Costs: The Organization allocated fringe benefits to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program more than the amount actually incurred by $99,699. The organization allocated fringe benefits to the Food Insecurity Nutrition Incentive Grants Program more than the amount actually incurred by $6,558.Context: During the review of the fringe benefits charged to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and the Food Insecurity Nutrition Incentive Grants Program, it was noted the amounts allocated for fringe benefits were in excess of the fringe incurred by the organization by $99,699 and $6,558, respectively. it was also noted management was unable to locate the supporting documentation for two transactions totaling $266. Cause: The Organization allocated fringe to the program based on the percentages included in the contract budget, as opposed to charging actual expenditures incurred to the grants. Management's internal controls did not prevent or detect the grants from being overcharged fringe benefits. In addition, the organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: Allocated costs that are not appropriately budgeted and invoiced could result in inaccurate reporting and misrepresentation of the program's expenses. If the organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust review the allocation process for fringe benefits to ensure amounts reflect a more accurate representation of the actual fringe benefits incurred by the Organization. In addition, the Food Trust should review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331Effect: The reconciliation of the program expenditures was not performed in a timely manner. This resulted in expenditures being charged to the program that were not allowable and funding may need to be returned to the pass-through agency. Repeat Finding: N/A: Not a repeat finding. Recommendation: Management should review its practices to ensure there are adequate review controls in place so only allowable costs are allocated to federal programs. In addition, the funding received for the questioned costs should be remitted back to the funder by the Organization. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan. Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412 Award Period: September 1, 2019 - August 31, 2022 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained and reviewed to support all transactions. Condition: The detail of the expenditures incurred for the program included a transaction for bad debt expense which is not an allowable cost per the program budgets. In addition, there was funding drawn down by the agency for this transaction. Questioned Costs: The Organization was reimbursed for $3,943 of unallowable costs. Context: During the review of program expenditure detail for the program, it was noted there was a transaction for bad debt expense that was not included in the budget as an allowable cost. Cause: The Organization had several key finance management positions turnover several times beginning in September 2019 through June 2021. There was an analysis performed by current management for this program which determined there was expenses incurred in prior years however not recognized as revenue until this reconciliation was performed in fiscal year 2022. This specific transaction was expensed in the year ended September 30, 2021. The charging to the federal program was an oversight by management.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to ensure adequate controls designed to ensure personnel costs are documented with time and effort certifications.Condition: During our testing, we noted the Organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the Organization is not completing time and effort certification for the actual time spent working on the program. Cause: The Organization did not have policies and procedures in place to adequately document and certify employee’s time and effort charged to the grant. Effect: When an organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications, it can lead to a lack of transparency and accountability in recording and reporting personnel costs. This can result in inaccurate financial statements and potential noncompliance with regulatory requirements. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to ensure adequate controls designed to ensure personnel costs are documented with time and effort certifications.Condition: During our testing, we noted the Organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the Organization is not completing time and effort certification for the actual time spent working on the program. Cause: The Organization did not have policies and procedures in place to adequately document and certify employee’s time and effort charged to the grant. Effect: When an organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications, it can lead to a lack of transparency and accountability in recording and reporting personnel costs. This can result in inaccurate financial statements and potential noncompliance with regulatory requirements. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to ensure adequate controls designed to ensure personnel costs are documented with time and effort certifications.Condition: During our testing, we noted the Organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the Organization is not completing time and effort certification for the actual time spent working on the program. Cause: The Organization did not have policies and procedures in place to adequately document and certify employee’s time and effort charged to the grant. Effect: When an organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications, it can lead to a lack of transparency and accountability in recording and reporting personnel costs. This can result in inaccurate financial statements and potential noncompliance with regulatory requirements. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to ensure adequate controls designed to ensure personnel costs are documented with time and effort certifications.Condition: During our testing, we noted the Organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the Organization is not completing time and effort certification for the actual time spent working on the program. Cause: The Organization did not have policies and procedures in place to adequately document and certify employee’s time and effort charged to the grant. Effect: When an organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications, it can lead to a lack of transparency and accountability in recording and reporting personnel costs. This can result in inaccurate financial statements and potential noncompliance with regulatory requirements. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Cash Management Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have procedures in place to ensure the draw down of federal funds in a timely manner and proper documentation of approval should be maintained to support the draw of funds. Condition: During our testing, we noted the same individual is both preparing and requesting the draw of funds for the program without any approval by another individual. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted the same individual is preparing and requesting the draw of funds for the program with no approval by another individual. Cause: The Organization had significant turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval represents a lack of segregation of duties and can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish a system of checks and balances that includes a separation of duties. This means that different individuals should be responsible for preparing and requesting the draw of funds, and there should be a clear approval process in place. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing proper segregation of duties, requiring approval from another individual and implementing a timely draw process, the Organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Cash Management Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have procedures in place to ensure the draw down of federal funds in a timely manner and proper documentation of approval should be maintained to support the draw of funds. Condition: During our testing, we noted the same individual is both preparing and requesting the draw of funds for the program without any approval by another individual. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted the same individual is preparing and requesting the draw of funds for the program with no approval by another individual. Cause: The Organization had significant turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval represents a lack of segregation of duties and can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish a system of checks and balances that includes a separation of duties. This means that different individuals should be responsible for preparing and requesting the draw of funds, and there should be a clear approval process in place. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing proper segregation of duties, requiring approval from another individual and implementing a timely draw process, the Organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Cash Management Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have procedures in place to ensure the draw down of federal funds in a timely manner and proper documentation of approval should be maintained to support the draw of funds. Condition: During our testing, we noted the same individual is both preparing and requesting the draw of funds for the program without any approval by another individual. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted the same individual is preparing and requesting the draw of funds for the program with no approval by another individual. Cause: The Organization had significant turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval represents a lack of segregation of duties and can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish a system of checks and balances that includes a separation of duties. This means that different individuals should be responsible for preparing and requesting the draw of funds, and there should be a clear approval process in place. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing proper segregation of duties, requiring approval from another individual and implementing a timely draw process, the Organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Cash Management Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have procedures in place to ensure the draw down of federal funds in a timely manner and proper documentation of approval should be maintained to support the draw of funds. Condition: During our testing, we noted the same individual is both preparing and requesting the draw of funds for the program without any approval by another individual. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted the same individual is preparing and requesting the draw of funds for the program with no approval by another individual. Cause: The Organization had significant turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval represents a lack of segregation of duties and can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish a system of checks and balances that includes a separation of duties. This means that different individuals should be responsible for preparing and requesting the draw of funds, and there should be a clear approval process in place. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing proper segregation of duties, requiring approval from another individual and implementing a timely draw process, the Organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561 and 10331 Pass-through Agency: The Pennsylvania State University and National Institute of Food and Agriculture Pass-through Number: S001650-COP-TFT; 2019-70030-30412; 2020-70030-33186; 2021-70034-34987; 2021-70034-35361 Award Period: October 1, 2021 - September 30, 2022; September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023; June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to accurately record and report fringe benefits based on the actual expenses incurred by the organization and to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained and reviewed to support all transactions. Condition: During our testing, we noted the Organization charges benefits to the programs based on an allocation calculated at 25% of salaries, but the actual benefits incurred are 20% of total salaries, there is a discrepancy between the allocated amount and the actual amount. We also noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $266 charged to the federal programs. Questioned Costs: The Organization allocated fringe benefits to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program more than the amount actually incurred by $99,699. The organization allocated fringe benefits to the Food Insecurity Nutrition Incentive Grants Program more than the amount actually incurred by $6,558.Context: During the review of the fringe benefits charged to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and the Food Insecurity Nutrition Incentive Grants Program, it was noted the amounts allocated for fringe benefits were in excess of the fringe incurred by the organization by $99,699 and $6,558, respectively. it was also noted management was unable to locate the supporting documentation for two transactions totaling $266. Cause: The Organization allocated fringe to the program based on the percentages included in the contract budget, as opposed to charging actual expenditures incurred to the grants. Management's internal controls did not prevent or detect the grants from being overcharged fringe benefits. In addition, the organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: Allocated costs that are not appropriately budgeted and invoiced could result in inaccurate reporting and misrepresentation of the program's expenses. If the organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust review the allocation process for fringe benefits to ensure amounts reflect a more accurate representation of the actual fringe benefits incurred by the Organization. In addition, the Food Trust should review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561 and 10331 Pass-through Agency: The Pennsylvania State University and National Institute of Food and Agriculture Pass-through Number: S001650-COP-TFT; 2019-70030-30412; 2020-70030-33186; 2021-70034-34987; 2021-70034-35361 Award Period: October 1, 2021 - September 30, 2022; September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023; June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to accurately record and report fringe benefits based on the actual expenses incurred by the organization and to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained and reviewed to support all transactions. Condition: During our testing, we noted the Organization charges benefits to the programs based on an allocation calculated at 25% of salaries, but the actual benefits incurred are 20% of total salaries, there is a discrepancy between the allocated amount and the actual amount. We also noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $266 charged to the federal programs. Questioned Costs: The Organization allocated fringe benefits to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program more than the amount actually incurred by $99,699. The organization allocated fringe benefits to the Food Insecurity Nutrition Incentive Grants Program more than the amount actually incurred by $6,558.Context: During the review of the fringe benefits charged to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and the Food Insecurity Nutrition Incentive Grants Program, it was noted the amounts allocated for fringe benefits were in excess of the fringe incurred by the organization by $99,699 and $6,558, respectively. it was also noted management was unable to locate the supporting documentation for two transactions totaling $266. Cause: The Organization allocated fringe to the program based on the percentages included in the contract budget, as opposed to charging actual expenditures incurred to the grants. Management's internal controls did not prevent or detect the grants from being overcharged fringe benefits. In addition, the organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: Allocated costs that are not appropriately budgeted and invoiced could result in inaccurate reporting and misrepresentation of the program's expenses. If the organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust review the allocation process for fringe benefits to ensure amounts reflect a more accurate representation of the actual fringe benefits incurred by the Organization. In addition, the Food Trust should review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561 and 10331 Pass-through Agency: The Pennsylvania State University and National Institute of Food and Agriculture Pass-through Number: S001650-COP-TFT; 2019-70030-30412; 2020-70030-33186; 2021-70034-34987; 2021-70034-35361 Award Period: October 1, 2021 - September 30, 2022; September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023; June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to accurately record and report fringe benefits based on the actual expenses incurred by the organization and to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained and reviewed to support all transactions. Condition: During our testing, we noted the Organization charges benefits to the programs based on an allocation calculated at 25% of salaries, but the actual benefits incurred are 20% of total salaries, there is a discrepancy between the allocated amount and the actual amount. We also noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $266 charged to the federal programs. Questioned Costs: The Organization allocated fringe benefits to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program more than the amount actually incurred by $99,699. The organization allocated fringe benefits to the Food Insecurity Nutrition Incentive Grants Program more than the amount actually incurred by $6,558.Context: During the review of the fringe benefits charged to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and the Food Insecurity Nutrition Incentive Grants Program, it was noted the amounts allocated for fringe benefits were in excess of the fringe incurred by the organization by $99,699 and $6,558, respectively. it was also noted management was unable to locate the supporting documentation for two transactions totaling $266. Cause: The Organization allocated fringe to the program based on the percentages included in the contract budget, as opposed to charging actual expenditures incurred to the grants. Management's internal controls did not prevent or detect the grants from being overcharged fringe benefits. In addition, the organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: Allocated costs that are not appropriately budgeted and invoiced could result in inaccurate reporting and misrepresentation of the program's expenses. If the organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust review the allocation process for fringe benefits to ensure amounts reflect a more accurate representation of the actual fringe benefits incurred by the Organization. In addition, the Food Trust should review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561 and 10331 Pass-through Agency: The Pennsylvania State University and National Institute of Food and Agriculture Pass-through Number: S001650-COP-TFT; 2019-70030-30412; 2020-70030-33186; 2021-70034-34987; 2021-70034-35361 Award Period: October 1, 2021 - September 30, 2022; September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023; June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to accurately record and report fringe benefits based on the actual expenses incurred by the organization and to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained and reviewed to support all transactions. Condition: During our testing, we noted the Organization charges benefits to the programs based on an allocation calculated at 25% of salaries, but the actual benefits incurred are 20% of total salaries, there is a discrepancy between the allocated amount and the actual amount. We also noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $266 charged to the federal programs. Questioned Costs: The Organization allocated fringe benefits to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program more than the amount actually incurred by $99,699. The organization allocated fringe benefits to the Food Insecurity Nutrition Incentive Grants Program more than the amount actually incurred by $6,558.Context: During the review of the fringe benefits charged to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and the Food Insecurity Nutrition Incentive Grants Program, it was noted the amounts allocated for fringe benefits were in excess of the fringe incurred by the organization by $99,699 and $6,558, respectively. it was also noted management was unable to locate the supporting documentation for two transactions totaling $266. Cause: The Organization allocated fringe to the program based on the percentages included in the contract budget, as opposed to charging actual expenditures incurred to the grants. Management's internal controls did not prevent or detect the grants from being overcharged fringe benefits. In addition, the organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: Allocated costs that are not appropriately budgeted and invoiced could result in inaccurate reporting and misrepresentation of the program's expenses. If the organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust review the allocation process for fringe benefits to ensure amounts reflect a more accurate representation of the actual fringe benefits incurred by the Organization. In addition, the Food Trust should review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561 and 10331 Pass-through Agency: The Pennsylvania State University and National Institute of Food and Agriculture Pass-through Number: S001650-COP-TFT; 2019-70030-30412; 2020-70030-33186; 2021-70034-34987; 2021-70034-35361 Award Period: October 1, 2021 - September 30, 2022; September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023; June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to accurately record and report fringe benefits based on the actual expenses incurred by the organization and to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained and reviewed to support all transactions. Condition: During our testing, we noted the Organization charges benefits to the programs based on an allocation calculated at 25% of salaries, but the actual benefits incurred are 20% of total salaries, there is a discrepancy between the allocated amount and the actual amount. We also noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $266 charged to the federal programs. Questioned Costs: The Organization allocated fringe benefits to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program more than the amount actually incurred by $99,699. The organization allocated fringe benefits to the Food Insecurity Nutrition Incentive Grants Program more than the amount actually incurred by $6,558.Context: During the review of the fringe benefits charged to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and the Food Insecurity Nutrition Incentive Grants Program, it was noted the amounts allocated for fringe benefits were in excess of the fringe incurred by the organization by $99,699 and $6,558, respectively. it was also noted management was unable to locate the supporting documentation for two transactions totaling $266. Cause: The Organization allocated fringe to the program based on the percentages included in the contract budget, as opposed to charging actual expenditures incurred to the grants. Management's internal controls did not prevent or detect the grants from being overcharged fringe benefits. In addition, the organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: Allocated costs that are not appropriately budgeted and invoiced could result in inaccurate reporting and misrepresentation of the program's expenses. If the organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust review the allocation process for fringe benefits to ensure amounts reflect a more accurate representation of the actual fringe benefits incurred by the Organization. In addition, the Food Trust should review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331Effect: The reconciliation of the program expenditures was not performed in a timely manner. This resulted in expenditures being charged to the program that were not allowable and funding may need to be returned to the pass-through agency. Repeat Finding: N/A: Not a repeat finding. Recommendation: Management should review its practices to ensure there are adequate review controls in place so only allowable costs are allocated to federal programs. In addition, the funding received for the questioned costs should be remitted back to the funder by the Organization. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan. Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412 Award Period: September 1, 2019 - August 31, 2022 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained and reviewed to support all transactions. Condition: The detail of the expenditures incurred for the program included a transaction for bad debt expense which is not an allowable cost per the program budgets. In addition, there was funding drawn down by the agency for this transaction. Questioned Costs: The Organization was reimbursed for $3,943 of unallowable costs. Context: During the review of program expenditure detail for the program, it was noted there was a transaction for bad debt expense that was not included in the budget as an allowable cost. Cause: The Organization had several key finance management positions turnover several times beginning in September 2019 through June 2021. There was an analysis performed by current management for this program which determined there was expenses incurred in prior years however not recognized as revenue until this reconciliation was performed in fiscal year 2022. This specific transaction was expensed in the year ended September 30, 2021. The charging to the federal program was an oversight by management.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to ensure adequate controls designed to ensure personnel costs are documented with time and effort certifications.Condition: During our testing, we noted the Organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the Organization is not completing time and effort certification for the actual time spent working on the program. Cause: The Organization did not have policies and procedures in place to adequately document and certify employee’s time and effort charged to the grant. Effect: When an organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications, it can lead to a lack of transparency and accountability in recording and reporting personnel costs. This can result in inaccurate financial statements and potential noncompliance with regulatory requirements. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to ensure adequate controls designed to ensure personnel costs are documented with time and effort certifications.Condition: During our testing, we noted the Organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the Organization is not completing time and effort certification for the actual time spent working on the program. Cause: The Organization did not have policies and procedures in place to adequately document and certify employee’s time and effort charged to the grant. Effect: When an organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications, it can lead to a lack of transparency and accountability in recording and reporting personnel costs. This can result in inaccurate financial statements and potential noncompliance with regulatory requirements. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to ensure adequate controls designed to ensure personnel costs are documented with time and effort certifications.Condition: During our testing, we noted the Organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the Organization is not completing time and effort certification for the actual time spent working on the program. Cause: The Organization did not have policies and procedures in place to adequately document and certify employee’s time and effort charged to the grant. Effect: When an organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications, it can lead to a lack of transparency and accountability in recording and reporting personnel costs. This can result in inaccurate financial statements and potential noncompliance with regulatory requirements. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures in place to ensure adequate controls designed to ensure personnel costs are documented with time and effort certifications.Condition: During our testing, we noted the Organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the Organization is not completing time and effort certification for the actual time spent working on the program. Cause: The Organization did not have policies and procedures in place to adequately document and certify employee’s time and effort charged to the grant. Effect: When an organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications, it can lead to a lack of transparency and accountability in recording and reporting personnel costs. This can result in inaccurate financial statements and potential noncompliance with regulatory requirements. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Cash Management Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have procedures in place to ensure the draw down of federal funds in a timely manner and proper documentation of approval should be maintained to support the draw of funds. Condition: During our testing, we noted the same individual is both preparing and requesting the draw of funds for the program without any approval by another individual. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted the same individual is preparing and requesting the draw of funds for the program with no approval by another individual. Cause: The Organization had significant turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval represents a lack of segregation of duties and can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish a system of checks and balances that includes a separation of duties. This means that different individuals should be responsible for preparing and requesting the draw of funds, and there should be a clear approval process in place. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing proper segregation of duties, requiring approval from another individual and implementing a timely draw process, the Organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Cash Management Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have procedures in place to ensure the draw down of federal funds in a timely manner and proper documentation of approval should be maintained to support the draw of funds. Condition: During our testing, we noted the same individual is both preparing and requesting the draw of funds for the program without any approval by another individual. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted the same individual is preparing and requesting the draw of funds for the program with no approval by another individual. Cause: The Organization had significant turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval represents a lack of segregation of duties and can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish a system of checks and balances that includes a separation of duties. This means that different individuals should be responsible for preparing and requesting the draw of funds, and there should be a clear approval process in place. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing proper segregation of duties, requiring approval from another individual and implementing a timely draw process, the Organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Cash Management Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have procedures in place to ensure the draw down of federal funds in a timely manner and proper documentation of approval should be maintained to support the draw of funds. Condition: During our testing, we noted the same individual is both preparing and requesting the draw of funds for the program without any approval by another individual. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted the same individual is preparing and requesting the draw of funds for the program with no approval by another individual. Cause: The Organization had significant turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval represents a lack of segregation of duties and can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish a system of checks and balances that includes a separation of duties. This means that different individuals should be responsible for preparing and requesting the draw of funds, and there should be a clear approval process in place. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing proper segregation of duties, requiring approval from another individual and implementing a timely draw process, the Organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Cash Management Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have procedures in place to ensure the draw down of federal funds in a timely manner and proper documentation of approval should be maintained to support the draw of funds. Condition: During our testing, we noted the same individual is both preparing and requesting the draw of funds for the program without any approval by another individual. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted the same individual is preparing and requesting the draw of funds for the program with no approval by another individual. Cause: The Organization had significant turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval represents a lack of segregation of duties and can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish a system of checks and balances that includes a separation of duties. This means that different individuals should be responsible for preparing and requesting the draw of funds, and there should be a clear approval process in place. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing proper segregation of duties, requiring approval from another individual and implementing a timely draw process, the Organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.