Audit 364615

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561; 10.331 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health; National Institute of Food and Agriculture; State of California, Department of Food and Agriculture Pass-through Number: S003654-COP; DFHS23SNA005; 2021-70034-34987; 2021-70034-35361; 22-1464-004-SF Award Period: October 1, 2023 - September 30, 2024; June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026; January 1, 2023 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 did not have approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees for the Food Insecurity Nutrition Incentive Grants Program. In addition, the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program it was identified there were eight employees tested that did not have time and effort documented for their time spent working on the New Jersey Corner store program. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employees’ 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: Yes - see finding 2023-002. 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: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Assistance Listing Number: 10.561 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health Pass-through Number: S004968-COP-TFT; DFHS24SNA005 Award Period: October 1, 2023 - September 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F - Audit Requirements, section 200.303 requires that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes verifying that vendors are not suspended or debarred before engaging in transactions. Condition: During our testing, we found that the Organization provided documentation showing that the vendors used in the federal program were not listed as suspended or debarred according to the Sam.gov website, in line with their internal control procedures. However, there was no documentation indicating that the verification was performed prior to entering the transactions. Questioned Costs: None Context: The absence of documentation confirming that vendors were screened for suspension or debarment before engaging in transactions represents a gap in internal control over compliance. This control measure is essential to adhere to Federal regulations and reduce the risk of conducting business with parties who are suspended or debarred. Cause: The Organization did not have a formal process in place to document the verification of suspension and debarment status prior to engaging with vendors. Effect: In the absence of documented evidence of vendor verification, there is an elevated risk that the Organization may engage in transactions with suspended or debarred parties. This situation could lead to noncompliance with Federal regulations and result in potential penalties. Repeat Finding: N/A – Not a repeat finding. Recommendation: The Organization should establish and enforce controls to verify that vendors are not suspended or debarred prior to entering any transactions and maintain this documentation. This measure ensures the integrity of the procurement process and mitigates risks associated with engaging disqualified vendors. In 2024, the threshold amount for suspension and debarment checks was $25,000. Transactions equal to or exceeding this amount required verification to confirm that the entity involved was not debarred or suspended. 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; Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561; 10.331 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health; National Institute of Food and Agriculture; State of California, Department of Food and Agriculture Pass-through Number: S003654-COP; DFHS23SNA005; 2021-70034-34987; 2021-70034-35361; 22-1464-004-SF Award Period: October 1, 2023 - September 30, 2024; June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026; January 1, 2023 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 did not have approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees for the Food Insecurity Nutrition Incentive Grants Program. In addition, the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program it was identified there were eight employees tested that did not have time and effort documented for their time spent working on the New Jersey Corner store program. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employees’ 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: Yes - see finding 2023-002. 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: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Assistance Listing Number: 10.561 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health Pass-through Number: S004968-COP-TFT; DFHS24SNA005 Award Period: October 1, 2023 - September 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F - Audit Requirements, section 200.303 requires that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes verifying that vendors are not suspended or debarred before engaging in transactions. Condition: During our testing, we found that the Organization provided documentation showing that the vendors used in the federal program were not listed as suspended or debarred according to the Sam.gov website, in line with their internal control procedures. However, there was no documentation indicating that the verification was performed prior to entering the transactions. Questioned Costs: None Context: The absence of documentation confirming that vendors were screened for suspension or debarment before engaging in transactions represents a gap in internal control over compliance. This control measure is essential to adhere to Federal regulations and reduce the risk of conducting business with parties who are suspended or debarred. Cause: The Organization did not have a formal process in place to document the verification of suspension and debarment status prior to engaging with vendors. Effect: In the absence of documented evidence of vendor verification, there is an elevated risk that the Organization may engage in transactions with suspended or debarred parties. This situation could lead to noncompliance with Federal regulations and result in potential penalties. Repeat Finding: N/A – Not a repeat finding. Recommendation: The Organization should establish and enforce controls to verify that vendors are not suspended or debarred prior to entering any transactions and maintain this documentation. This measure ensures the integrity of the procurement process and mitigates risks associated with engaging disqualified vendors. In 2024, the threshold amount for suspension and debarment checks was $25,000. Transactions equal to or exceeding this amount required verification to confirm that the entity involved was not debarred or suspended. 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; Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561; 10.331 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health; National Institute of Food and Agriculture; State of California, Department of Food and Agriculture Pass-through Number: S003654-COP; DFHS23SNA005; 2021-70034-34987; 2021-70034-35361; 22-1464-004-SF Award Period: October 1, 2023 - September 30, 2024; June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026; January 1, 2023 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 did not have approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees for the Food Insecurity Nutrition Incentive Grants Program. In addition, the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program it was identified there were eight employees tested that did not have time and effort documented for their time spent working on the New Jersey Corner store program. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employees’ 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: Yes - see finding 2023-002. 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: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561; 10.331 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health; National Institute of Food and Agriculture; State of California, Department of Food and Agriculture Pass-through Number: S003654-COP; DFHS23SNA005; 2021-70034-34987; 2021-70034-35361; 22-1464-004-SF Award Period: October 1, 2023 - September 30, 2024; June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026; January 1, 2023 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 did not have approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees for the Food Insecurity Nutrition Incentive Grants Program. In addition, the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program it was identified there were eight employees tested that did not have time and effort documented for their time spent working on the New Jersey Corner store program. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employees’ 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: Yes - see finding 2023-002. 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: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561; 10.331 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health; National Institute of Food and Agriculture; State of California, Department of Food and Agriculture Pass-through Number: S003654-COP; DFHS23SNA005; 2021-70034-34987; 2021-70034-35361; 22-1464-004-SF Award Period: October 1, 2023 - September 30, 2024; June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026; January 1, 2023 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 did not have approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees for the Food Insecurity Nutrition Incentive Grants Program. In addition, the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program it was identified there were eight employees tested that did not have time and effort documented for their time spent working on the New Jersey Corner store program. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employees’ 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: Yes - see finding 2023-002. 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: 2021-70034-34987; 2021-70034-35361 Award Period: June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 there was no documentation of review or approval on the calculation for the draw of funding for the program. 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 there was no documentation of review or approval on the calculations for the draw of funding for the program. Cause: The organization had 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 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: Yes - see finding 2023-003. Recommendation: We recommend The Food Trust implement a clear approval process for the drawing of federal funding. 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 an approval and 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: 2021-70034-34987; 2021-70034-35361 Award Period: June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 there was no documentation of review or approval on the calculation for the draw of funding for the program. 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 there was no documentation of review or approval on the calculations for the draw of funding for the program. Cause: The organization had 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 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: Yes - see finding 2023-003. Recommendation: We recommend The Food Trust implement a clear approval process for the drawing of federal funding. 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 an approval and 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: 2021-70034-34987; 2021-70034-35361 Award Period: June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 there was no documentation of review or approval on the calculation for the draw of funding for the program. 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 there was no documentation of review or approval on the calculations for the draw of funding for the program. Cause: The organization had 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 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: Yes - see finding 2023-003. Recommendation: We recommend The Food Trust implement a clear approval process for the drawing of federal funding. 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 an approval and 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; Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561; 10.331 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health; National Institute of Food and Agriculture; State of California, Department of Food and Agriculture Pass-through Number: S003654-COP; DFHS23SNA005; 2021-70034-34987; 2021-70034-35361; 22-1464-004-SF Award Period: October 1, 2023 - September 30, 2024; June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026; January 1, 2023 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 did not have approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees for the Food Insecurity Nutrition Incentive Grants Program. In addition, the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program it was identified there were eight employees tested that did not have time and effort documented for their time spent working on the New Jersey Corner store program. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employees’ 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: Yes - see finding 2023-002. 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: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Assistance Listing Number: 10.561 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health Pass-through Number: S004968-COP-TFT; DFHS24SNA005 Award Period: October 1, 2023 - September 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F - Audit Requirements, section 200.303 requires that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes verifying that vendors are not suspended or debarred before engaging in transactions. Condition: During our testing, we found that the Organization provided documentation showing that the vendors used in the federal program were not listed as suspended or debarred according to the Sam.gov website, in line with their internal control procedures. However, there was no documentation indicating that the verification was performed prior to entering the transactions. Questioned Costs: None Context: The absence of documentation confirming that vendors were screened for suspension or debarment before engaging in transactions represents a gap in internal control over compliance. This control measure is essential to adhere to Federal regulations and reduce the risk of conducting business with parties who are suspended or debarred. Cause: The Organization did not have a formal process in place to document the verification of suspension and debarment status prior to engaging with vendors. Effect: In the absence of documented evidence of vendor verification, there is an elevated risk that the Organization may engage in transactions with suspended or debarred parties. This situation could lead to noncompliance with Federal regulations and result in potential penalties. Repeat Finding: N/A – Not a repeat finding. Recommendation: The Organization should establish and enforce controls to verify that vendors are not suspended or debarred prior to entering any transactions and maintain this documentation. This measure ensures the integrity of the procurement process and mitigates risks associated with engaging disqualified vendors. In 2024, the threshold amount for suspension and debarment checks was $25,000. Transactions equal to or exceeding this amount required verification to confirm that the entity involved was not debarred or suspended. 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; Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561; 10.331 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health; National Institute of Food and Agriculture; State of California, Department of Food and Agriculture Pass-through Number: S003654-COP; DFHS23SNA005; 2021-70034-34987; 2021-70034-35361; 22-1464-004-SF Award Period: October 1, 2023 - September 30, 2024; June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026; January 1, 2023 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 did not have approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees for the Food Insecurity Nutrition Incentive Grants Program. In addition, the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program it was identified there were eight employees tested that did not have time and effort documented for their time spent working on the New Jersey Corner store program. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employees’ 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: Yes - see finding 2023-002. 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: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Assistance Listing Number: 10.561 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health Pass-through Number: S004968-COP-TFT; DFHS24SNA005 Award Period: October 1, 2023 - September 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F - Audit Requirements, section 200.303 requires that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes verifying that vendors are not suspended or debarred before engaging in transactions. Condition: During our testing, we found that the Organization provided documentation showing that the vendors used in the federal program were not listed as suspended or debarred according to the Sam.gov website, in line with their internal control procedures. However, there was no documentation indicating that the verification was performed prior to entering the transactions. Questioned Costs: None Context: The absence of documentation confirming that vendors were screened for suspension or debarment before engaging in transactions represents a gap in internal control over compliance. This control measure is essential to adhere to Federal regulations and reduce the risk of conducting business with parties who are suspended or debarred. Cause: The Organization did not have a formal process in place to document the verification of suspension and debarment status prior to engaging with vendors. Effect: In the absence of documented evidence of vendor verification, there is an elevated risk that the Organization may engage in transactions with suspended or debarred parties. This situation could lead to noncompliance with Federal regulations and result in potential penalties. Repeat Finding: N/A – Not a repeat finding. Recommendation: The Organization should establish and enforce controls to verify that vendors are not suspended or debarred prior to entering any transactions and maintain this documentation. This measure ensures the integrity of the procurement process and mitigates risks associated with engaging disqualified vendors. In 2024, the threshold amount for suspension and debarment checks was $25,000. Transactions equal to or exceeding this amount required verification to confirm that the entity involved was not debarred or suspended. 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; Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561; 10.331 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health; National Institute of Food and Agriculture; State of California, Department of Food and Agriculture Pass-through Number: S003654-COP; DFHS23SNA005; 2021-70034-34987; 2021-70034-35361; 22-1464-004-SF Award Period: October 1, 2023 - September 30, 2024; June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026; January 1, 2023 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 did not have approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees for the Food Insecurity Nutrition Incentive Grants Program. In addition, the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program it was identified there were eight employees tested that did not have time and effort documented for their time spent working on the New Jersey Corner store program. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employees’ 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: Yes - see finding 2023-002. 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: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561; 10.331 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health; National Institute of Food and Agriculture; State of California, Department of Food and Agriculture Pass-through Number: S003654-COP; DFHS23SNA005; 2021-70034-34987; 2021-70034-35361; 22-1464-004-SF Award Period: October 1, 2023 - September 30, 2024; June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026; January 1, 2023 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 did not have approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees for the Food Insecurity Nutrition Incentive Grants Program. In addition, the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program it was identified there were eight employees tested that did not have time and effort documented for their time spent working on the New Jersey Corner store program. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employees’ 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: Yes - see finding 2023-002. 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: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561; 10.331 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health; National Institute of Food and Agriculture; State of California, Department of Food and Agriculture Pass-through Number: S003654-COP; DFHS23SNA005; 2021-70034-34987; 2021-70034-35361; 22-1464-004-SF Award Period: October 1, 2023 - September 30, 2024; June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026; January 1, 2023 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 did not have approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees for the Food Insecurity Nutrition Incentive Grants Program. In addition, the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program it was identified there were eight employees tested that did not have time and effort documented for their time spent working on the New Jersey Corner store program. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employees’ 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: Yes - see finding 2023-002. 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: 2021-70034-34987; 2021-70034-35361 Award Period: June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 there was no documentation of review or approval on the calculation for the draw of funding for the program. 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 there was no documentation of review or approval on the calculations for the draw of funding for the program. Cause: The organization had 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 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: Yes - see finding 2023-003. Recommendation: We recommend The Food Trust implement a clear approval process for the drawing of federal funding. 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 an approval and 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: 2021-70034-34987; 2021-70034-35361 Award Period: June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 there was no documentation of review or approval on the calculation for the draw of funding for the program. 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 there was no documentation of review or approval on the calculations for the draw of funding for the program. Cause: The organization had 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 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: Yes - see finding 2023-003. Recommendation: We recommend The Food Trust implement a clear approval process for the drawing of federal funding. 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 an approval and 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: 2021-70034-34987; 2021-70034-35361 Award Period: June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters 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 there was no documentation of review or approval on the calculation for the draw of funding for the program. 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 there was no documentation of review or approval on the calculations for the draw of funding for the program. Cause: The organization had 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 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: Yes - see finding 2023-003. Recommendation: We recommend The Food Trust implement a clear approval process for the drawing of federal funding. 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 an approval and 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.