Audit 391133

AL number: 10.568, 10.569, 10.565 AL title: Emergency Food Assistance Program – Food Distribution Cluster Compliance requirement: Special Tests and Provisions Name of federal agency: U.S. Department of Agriculture Name of pass-through entity: Illinois Department of Human Services and Missouri Department of Social Services Type of finding: Material Weakness in Internal Control over Compliance of Major Programs Criteria: St. Louis Area Food Bank, Inc. is responsible for maintaining effective internal controls over compliance with Special Tests and Provisions. Proper controls require that documentation supporting food commodity receipts, including inspection reports and bills of lading, be complete, signed, and retained to ensure accountability and compliance with federal requirements. Condition: During our audit, we noted that required documentation was not consistently maintained. Specifically, the inspection report (lading report) was not completed or signed during the intake process, and for one receipt, neither the inspection report nor the bill of lading could be obtained for testing on another receipt. These issues indicate a breakdown in internal controls over documentation and verification of food receipts. Cause: The deficiencies appear to result from insufficient oversight and high staff turnover in the warehouse, combined with onboarding of new employees who may not yet be fully familiar with the program’s documentation requirements and procedures. Possible effect: Incomplete or unsigned documentation indicates a failure in the program’s internal controls, increases the risk of noncompliance with federal requirements, and may hinder the ability to verify service delivery of receipts and inventory accountability. Questioned cost: None Recommendation: We recommend management reinforce documentation procedures through staff training and implement a mandatory review process to ensure inspection reports and bills of lading are completed, signed, and retained for all receipts of food commodities. Additionally, periodic internal reviews should be conducted to monitor compliance and address recurring issues promptly.

AL number: 10.568, 10.569, 10.565 AL title: Emergency Food Assistance Program – Food Distribution Cluster Compliance requirement: Special Tests and Provisions Name of federal agency: U.S. Department of Agriculture Name of pass-through entity: Illinois Department of Human Services and Missouri Department of Social Services Type of finding: Significant Deficiency in Internal Control over Compliance of Major Programs Criteria: St. Louis Area Food Bank, Inc. is responsible for implementing and maintaining an effective internal control system over compliance with Special Tests and Provisions. A proper internal control system requires that documentation supporting compliance with program requirements, including inventory distributions, be accurate, complete, and timely to ensure accountability and prevent errors or misstatements. Condition: During the audit, we noted that documentation procedures were not consistently followed. Specifically, two invoice forms of the twenty tested were missing staff signatures. These instances indicate a breakdown in internal controls related to documentation and verification processes. Cause: The deficiencies appear to result from inadequate oversight during intake procedures and high staff turnover, which led to inconsistent adherence to documentation requirements. Possible effect: Failure to complete and retain required documentation compromises the integrity of internal controls, increases the risk of noncompliance with federal requirements, and limits the ability to verify proper food distribution, eligibility, and inventory accountability. Questioned cost: None Recommendation: We recommend that management strengthen internal controls over documentation by reinforcing established procedures through targeted staff training and regular reminders to ensure compliance. Additionally, management should implement a review or checklist process to verify that all required forms are completed and signed prior to finalization. To further enhance oversight, periodic internal audits should be conducted to monitor adherence to documentation requirements and promptly address any recurring issues.

AL number: 10.568, 10.569, 10.565 AL title: Emergency Food Assistance Program – Food Distribution Cluster Compliance requirement Special Tests and Provisions Name of federal agency: U.S. Department of Agriculture Name of pass-through entity: Illinois Department of Human Services and Missouri Department of Social Services Type of finding: Compliance Finding – Noncompliance with Federal Program Requirements Criteria: Federal regulations require that recipients maintain complete and accurate documentation for food commodities, including inspection reports and bills of lading, to demonstrate compliance with Special Tests and Provisions and ensure accountability for inventory received and distributed. Condition: During our audit, we were unable to obtain the inspection report and bill of lading for one food commodity receipt of the twenty tested. The absence of these documents prevented us from performing required compliance testing and verifying adherence to federal requirements. Cause: The deficiency appears to result from inadequate retention of documentation and insufficient oversight of intake procedures, compounded by staff turnover and onboarding challenges.Possible effect: Failure to maintain required documentation constitutes noncompliance with federal program requirements, limits the ability to verify proper food inventory tracking, including receipts and distributions, and increases the risk of errors or misstatements in reporting. Questioned cost: None Recommendation: We recommend management implement stronger controls over document retention by establishing clear procedures for collecting, signing, and storing inspection reports and bills of lading. Additionally, management should provide training to staff and conduct periodic internal reviews to ensure compliance with documentation requirements.