Audit 368888

Finding No. 2024-003 – Procurement Federal Agency: U.S. Department of Agriculture Federal Program: Special Supplement Nutrition Program for Women, Infants, and Children Assistance Listing No.: 10.557 Federal Award Identification No. and Year: 238DC000M2003 (2023) Pass-through Agency: Food Research and Action Center Pass-through No.: V5KQJY61BB96 Award Period: May 1, 2023 through October 31, 2024 Type of Finding: Significant Deficiency in Internal Control and Other Matter Criteria or Specific Requirement: Non-federal entities are required by Uniform Guidance to comply with, and to establish and maintain effective internal control over compliance with, federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our audit, we identified that ACHD did comply with, or establish adequate internal control over compliance with, federal procurement requirements as mandated by Uniform Guidance. Questioned Costs: None Context: The procurement policies of ACHD, specifically its micro-purchase threshold, does not comply with the minimum threshold required by Uniform Guidance. Effect: Lack of compliance, and lack of internal control over compliance, could result in noncompliance with federal procurement requirements, potentially leading to penalties or loss of federal funding. Cause: ACHD did not update its purchasing policy to align with Uniform Guidance. Recommendation: We recommend that ACHD update its purchasing policy to align with Uniform Guidance.

Finding No. 2024-004 – Indirect Costs, Cash Management, and Reporting Federal Agency: U.S. Department of Agriculture U.S. Department of Health and Human Services Federal Program: Special Supplement Nutrition Program for Women, Infants, and Children Collaboration with Academia to Strengthen Public Health Assistance Listing No.: 10.557 93.967 Federal Award Identification No. and Year: 238DC000M2003 (2023) 3MO700804-2023, 3MO700704-2024 5NE11OE00072-02-00 (2023) 1NE11OE000072-01 | 6NE11OE000072-01 (2023) Pass-through Agency: Food Research and Action Center Missouri Department of Health and Senior Services Pass-through No.: V5KQJY61BB96 ERS04524018 | ERS04525001 DH2400055278 | DH240054229 Award Period: May 1, 2023 through September 30, 2025 August 1, 2023 through November 30, 2027 Type of Finding: Significant Deficiency in Internal Control Criteria or Specific Requirement: Non-federal entities are required by Uniform Guidance to establish and maintain effective internal control over compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our audit, we identified that ACHD did not establish adequate internal control over compliance with federal allowable activities/costs (specifically indirect costs), cash management, or reporting requirements as mandated by Uniform Guidance. Questioned Costs: None Context: We noted that reimbursement requests and performance reports, prior to being submitted to the grantor, are not reviewed and approved by someone other than the preparer. Effect: Lack of internal control over compliance could result in noncompliance with federal allowable activities/costs (specifically indirect costs), cash management, or reporting requirements, potentially leading to penalties or loss of federal funding. Cause: ACHD does not have an internal control policy in place that requires reimbursement requests and performance reports to be reviewed and approved by someone other than the preparer prior to being submitted to the grantor. Recommendation: ACHD should ensure that reimbursement requests and performance reports are reviewed and approved by someone other than the preparer prior to being submitted to the grantor and that reviews and approvals are documented.

Finding No. 2024-005 – Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program: Special Supplement Nutrition Program for Women, Infants, and Children Assistance Listing No.: 10.557 Federal Award Identification No. and Year: 238DC000M2003 (2023) Pass-through Agency: Food Research and Action Center Pass-through No.: V5KQJY61BB96 Award Period: May 1, 2023 through October 31, 2024 Type of Finding: Significant Deficiency in Internal Control Criteria or Specific Requirement: Non-federal entities are required by Uniform Guidance to establish and maintain effective internal control over compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: During our audit, we identified that ACHD did not establish adequate internal control over compliance with federal suspension and debarment requirements as mandated by Uniform Guidance. Questioned Costs: None Context: We noted that suspension and debarment verification procedures were not performed prior to engaging in a contract for 1 of 1 vendors tested. Effect: Lack of internal control over compliance could result in noncompliance with federal suspension and debarment requirements, potentially leading to penalties or loss of federal funding. Cause: ACHD does not have an internal control policy in place that requires suspension and debarment verification procedures to be performed prior to engaging in a contract. Recommendation: For all contracts charged to federal programs, ACHD should ensure that suspension and debarment verification procedures are performed prior to engaging in the contract.