Audit 369170

2023-003 Commodity Supplemental Food Program (CSFP) Eligibility Criteria [ ] Compliance Finding [ ] Significant Deficiency [X] Material Weakness OMB 2 CFR 200, Subpart F Compliance Supplement, Part 4, Compliance Requirement E, Eligibility states, “A local agency certifies households as eligible to receive a CSFP food package by applying categorical and income eligible criteria. Eligibility is limited to the elderly (persons at least 60 years of age) (7 CFR section 247.9(a)).” Condition During our testing of eligibility of the CSFP program, we noted eight exceptions where the Organization did not document the source of identification for which age of the recipient of food was determined. We also noted one exception for which an application did not have adequate documentation of approval. Cause The Organization did not have a formal process to document and review CSFP applications. Context The finding appears to be a systemic problem. Effect Incomplete or inaccurate applications could indicate that individuals may have not been eligible to receive food benefits. Recommendation We recommend that the Organization implement appropriate controls and review over the CSFP application process and maintain appropriate records to ascertain the eligibility of recipients of food benefits. View of responsible officials and planned corrective action We have implemented a CSFP application system that requires each element of the application to comply with eligibility standards before continuing to the next step.

2023-004 The Emergency Food Assistance Program (TEFAP) and Commodity Supplemental Food Program (CSFP) Reporting Criteria [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness OMB 2 CFR 200, Subpart F Compliance Supplement, Part 4, Compliance Requirement N, Special Tests and Provisions states, “Accurate and complete records must be maintained with respect to the receipt, distribution/use, and inventory of USDA Foods, including end products processed from USDA Foods in TEFAP. Failure to maintain records required by 7 CFR section 250.19 is considered prima facie evidence of improper distribution or loss of USDA Foods, and the agency processor or entity is liable for the value of the food or replacement of the food in kind (7 CFR sections 250.16 and 250.19(a)). State distributing agencies must conduct an annual physical inventory of all storage facilities used by the distributing agency or by a subdistributing agency. Such inventory must be reconciled annually with the storage facility’s inventory records and maintained on file by the agency which contracted with, or maintained, the storage facility. Corrective action must be taken immediately on all deficiencies and inventory discrepancies and the results of the corrective action forwarded to the distributing agency (7 CFR section 250.12(b)). In Commodity Supplemental Food Program (CSFP), a physical inventory also must be conducted annually at all storage and distribution sites where USDA Foods are stored (7 CFR section 247.28).” Condition During our testing of TEFAP records, the Organization did not maintain accurate records to distinguish TEFAP food receipts and usage from other food assistance received. Furthermore, during our testing of CSFP records, the Organization did not maintain documentation to track distribution of CSFP foods to participants that could be traced back to the USDA reports. Cause The Organization did not have a formal process to separately track TEFAP food receipts. The Organization did not have a formal process to track CSFP distributions that tied back to the USDA records. Context The finding appears to be a systemic problem. Effect Incomplete records could indicate that revenues and award expenditures were misstated or incorrectly reported. Recommendation We recommend that the Organization implement a process to track TEFAP food receipts and usage and CSFP food usage to ensure accurate reporting of USDA food. View of responsible officials and planned corrective action This error was identified in preparation of the 2024 audit in July 2025. We have implemented a system to track federal noncash award inflows and outflows according to bills of lading provided by the Contractor. We will reconcile our inventory at a minimum annually.