Audit 403667

2025-001 Suspension and Debarment Finding Type: Material Weakness in Internal Controls over Compliance and Compliance Federal Program Title and AL Number: The Emergency Food Assistance Program (TEFAP) Commodity Credit Corporation Eligible Recipient Funds (10.187). Criteria: Per Title 2 CFR § 180.300, non-federal entities that enter into a covered transaction with an entity at a lower tier are required to verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. Covered transactions includes all non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount. Condition and context: As part of our suspension and debarment testing, and in order to determine compliance with the requirements, we verified that the suspension or debarment verification check for subrecipient agencies were performed prior to entering into agreements with these agencies. For all four non-statistical samples, the verification check was performed subsequent to when the Food Bank entered into the contract with the agency. None of the agencies selected were suspended or debarred. Cause: The Food Bank did not have controls in place to ensure the suspension or debarment verifications were performed when entering into agreements with agencies. Effect: The Food Bank was not able to demonstrate compliance with 2 CFR § 180.300. Questioned Costs: None Repeat finding: Yes, 2024-001 Recommendation: We recommend that the Food Bank implement controls to ensure covered transactions with agencies at a lower tier are not suspended or debarred. Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.

2025-002 Suspension and Debarment Finding Type: Material Weakness in Internal Controls over Compliance and Compliance Federal Program Title and AL Number: The Food Distribution Cluster (10.565, 10.568, 10.569). Criteria: Per Title 2 CFR § 180.300, non-federal entities that enter into a covered transaction with an entity at a lower tier are required to verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. Covered transactions includes all non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount. Condition and context: As part of our suspension and debarment testing, and in order to determine compliance with the requirements, we verified that the suspension or debarment verification check for subrecipient agencies were performed prior to entering into agreements with these agencies. For all four non-statistical samples, the verification check was performed subsequent to when the Food Bank entered into the contract with the agency. None of the agencies selected were suspended or debarred. Cause: The Food Bank did not have controls in place to ensure the suspension or debarment verifications were performed when entering into agreements with agencies. Effect: The Food Bank was not able to demonstrate compliance with 2 CFR § 180.300. Questioned Costs: None Repeat finding: No Recommendation: We recommend that the Food Bank implement controls to ensure covered transactions with agencies at a lower tier are not suspended or debarred. Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.

2025-003 Eligibility Finding Type: Significant deficiency in Internal Controls over Compliance and Compliance Federal Program Title and AL Number: The Food Distribution Cluster (10.565, 10.568, 10.569). Criteria: Per Title 7 CFR § 247.8, to apply for or to be recertified for CSFP benefits, the applicant or caretaker of the applicant of his or her rights and responsibilities, in accordance with § 247.12, the local agency must ensure that the applicant or caretaker signs the application form. Condition and context: As part of our eligibility testing, and in order to determine compliance with the requirements, we verified that the CSFP participants had completed and signed applications or recertifications prior to receiving food distributions. For four out of 32 non-statistical samples, the application was completed but did not have the participants' signature. Cause: The Food Bank did not have controls in place to ensure the participant signatures were received prior to providing food assistance to the individual. Effect: The Food Bank was not able to demonstrate compliance with Title 7 CFR § 247.8. Questioned Costs: None Repeat finding: No Recommendation: We recommend the Food Bank implement controls to ensure CSFP applications and recertifications are signed by the applicant prior to the individual receiving food. Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.