Audit 63

ALN # 93.558 – Temporary Assistance for Needy Families (TANF) U.S. Department of Health and Human Services Criteria: Under the requirements of the Office of Management and Budget, only a financially needy family that consists of, at a minimum, a minor child living with a parent or other caretaker relative, or a pregnant woman may receive TANF “assistance” or most maintenance-of-effort funded benefits, services or “assistance”. The child must be less than 18 years old, or, if a full-time student in a secondary school (or the equivalent level of vocational or technical training), less than 19 years old. Freestore Foodbank Inc. and Affiliates require all individuals receiving food to complete an eligibility form prior to receiving food. Condition: We noted one instance (in a sample of 40 clients) in which an eligibility form was not obtained prior to client receiving food. Context: Electronic eligibility form was not retained. Cause: Electronic system did not operate as intended and there were no detective controls in place to identify the missing form. Effect: Freestore Foodbank, Inc. and Affiliates’ internal controls did not operate as designed and was unable to verify compliance with eligibility requirements. Recommendation: Freestore Foodbank should perform periodic internal audits of eligibility forms to ensure proper documentation is retained. Management’s Response: See corrective action plan on page 33.

ALN # 93.558 – Temporary Assistance for Needy Families (TANF) U.S. Department of Health and Human Services Criteria: According to 45 CFR 260.34, a religious organization that received Federal TANF funds shall not, in providing program services or benefits, discriminate against a TANF applicant or recipient on the basis of religion, a religious belief, a refusal to hold a religious belief, or a refusal to actively participate in a religious practice. To ensure compliance with this requirement, Freestore Foodbank Inc. and Affiliates require all local distributors receiving commodities to sign a local distributor agreement. Condition: CSH noted two instances (in a sample of 40 local distributor agreements) where food was distributed to religious organizations that do not abide by 45 CFR 260.34. Context: Local Distributors did not sign agreements prior to obtaining TANF commodities. Cause: Requests for commodities were entered outside of the online purchasing platform. Effect: Freestore Foodbank, Inc. and Affiliates’ internal controls were bypassed and commodities were distributed to unallowable local distributors. Recommendation: Freestore Foodbank Inc. and Affiliates should implement a reconciliation process to ensure all local distributors that receive USDA food have a signed local distributor agreement. Management’s Response: See corrective action plan on page 33.

ALN # 93.558 – Temporary Assistance for Needy Families (TANF) U.S. Department of Health and Human Services Criteria: Under the requirements of the Office of Management and Budget, only a financially needy family that consists of, at a minimum, a minor child living with a parent or other caretaker relative, or a pregnant woman may receive TANF “assistance” or most maintenance-of-effort funded benefits, services or “assistance”. The child must be less than 18 years old, or, if a full-time student in a secondary school (or the equivalent level of vocational or technical training), less than 19 years old. Freestore Foodbank Inc. and Affiliates require all individuals receiving food to complete an eligibility form prior to receiving food. Condition: We noted one instance (in a sample of 40 clients) in which an eligibility form was not obtained prior to client receiving food. Context: Electronic eligibility form was not retained. Cause: Electronic system did not operate as intended and there were no detective controls in place to identify the missing form. Effect: Freestore Foodbank, Inc. and Affiliates’ internal controls did not operate as designed and was unable to verify compliance with eligibility requirements. Recommendation: Freestore Foodbank should perform periodic internal audits of eligibility forms to ensure proper documentation is retained. Management’s Response: See corrective action plan on page 33.

ALN # 93.558 – Temporary Assistance for Needy Families (TANF) U.S. Department of Health and Human Services Criteria: According to 45 CFR 260.34, a religious organization that received Federal TANF funds shall not, in providing program services or benefits, discriminate against a TANF applicant or recipient on the basis of religion, a religious belief, a refusal to hold a religious belief, or a refusal to actively participate in a religious practice. To ensure compliance with this requirement, Freestore Foodbank Inc. and Affiliates require all local distributors receiving commodities to sign a local distributor agreement. Condition: CSH noted two instances (in a sample of 40 local distributor agreements) where food was distributed to religious organizations that do not abide by 45 CFR 260.34. Context: Local Distributors did not sign agreements prior to obtaining TANF commodities. Cause: Requests for commodities were entered outside of the online purchasing platform. Effect: Freestore Foodbank, Inc. and Affiliates’ internal controls were bypassed and commodities were distributed to unallowable local distributors. Recommendation: Freestore Foodbank Inc. and Affiliates should implement a reconciliation process to ensure all local distributors that receive USDA food have a signed local distributor agreement. Management’s Response: See corrective action plan on page 33.