Audit 414962

2024-003 Written Financial Policies Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments; ALN 10.182; U.S. Department of Agriculture Coronavirus State and Local Fiscal Recovery Funds; ALN 21.027; U.S. Department of Treasury Finding Type: Material Weakness and Material Noncompliance Condition: There were no formal, documented federal policies and procedures in place for December 31, 2024, as required by the Uniform Guidance. Criteria: The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and conflict of interest policy) (§200.318); and 3) Allowability of costs charged to federal programs (§200.302 (7)). Cause: Documented federal policies and procedures were not created and implemented by the Organization. Effect: As the result of this condition, Toledo Northwestern Ohio Food Bank, Inc. did not fully comply with the Uniform Guidance applicable to the major federal program. Recommendation: We recommend that the Organization prepare the required written policies and procedures as soon as practical. Organization’s Response: The Organization concurs with the facts of this finding and as of May 14, 2025 has implemented documented federal policies and procedures.

2024-004 Timeliness of Reporting Audited Financial Statements and Federal Awards Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments; ALN 10.182; U.S. Department of Agriculture Coronavirus State and Local Fiscal Recovery Funds; ALN 21.027; U.S. Department of Treasury Finding Type: Material Weakness and Material Noncompliance Condition: The Organization’s data collection form and the reporting package for the year ended December 31, 2024, was not submitted to the Federal Audit Clearinghouse (FAC) within a timely manner. Criteria: Under the audit requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance), auditees are required to submit the data collection form and the reporting package to the FAC within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Cause: The Organization did not have established controls in place to ensure timely submission to the Federal Audit Clearinghouse due to significant turnover in the finance department. Effect: The Organization did not meet the criteria for a low-risk auditee in the current year. Recommendation: The Organization should implement procedures and controls to effectively monitor the status of the submission of the data collection form and the reporting package to ensure that the required information is submitted in a timely manner. Organization’s Response: The Organization concurs with the facts of this finding and is implementing procedures to prevent this in the future.

2024-005 Timeliness of Reporting Required under Funding Agreements Coronavirus State and Local Fiscal Recovery Funds; ALN 21.027; U.S. Department of Treasury Finding Type: Significant Deficiency and Material Noncompliance Condition: Based on analysis, the Organization submitted four out of twelve monthly food distribution reports and two out of two financial statement packages reviewed outside of the reporting window established by its funding agreements with the Ohio Association of Food Banks. Criteria: Under the requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance), auditees are to submit required reporting in accordance with established reporting requirements. Cause: The Organization did not have effective controls in place to ensure timely submission of required information to funding organization. Effect: Untimely submission of required reporting to Ohio Association of Food Banks Recommendation: The Organization should implement procedures and controls to provide multiple redundancies related to reporting dates. Organization’s Response: The Organization concurs with the facts of this finding and is implementing procedures to prevent this in the future.