Audit 8540

Type of finding: Federal Award Situation: Significant deficiency; Compliance with federal regulations. Assistance Listing No: All Programs Compliance Requirements: Reporting Prior-Year(s) Audit Finding(s): 2020-003, 2019-003, 2018-003, 2017-008 Questioned Costs: Not determined. Condition: The Single Audit reporting package, as defined and required in 2 CRF 200.512 for fiscal year ended June 30, 2022, was not submitted timely. Context: AEDA’ Single Audit Reports have been submitted after the due date since fiscal year 2017. Criteria: As per 2 CRF 200.512, the audit, data collection form, and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period. However, for any 2022 submissions with fiscal periods ending between January 1, 2022, and October 31, 2022, the requirement stating that single audits are due to the Federal Audit Clearinghouse 30 days after receipt of the auditor’s report(s), is waived. These audits will be considered on time if they are submitted within nine months after their fiscal period end date. Cause: AEDA has not been able to provide the necessary information for the preparation of the Single Audit Report on a timely basis. Effect: AEDA did not comply with the report submission requirement since the audit was not submitted within nine months after their fiscal period end date. Auditor’s recommendation: Management should continue to fulfill their auditee responsibilities as stated in 2 CRF 200.508 which among other things, require management to prepare appropriate financial statements and provide the auditor with access to personnel, accounts, books, records, supporting documentation, and other information as needed for the auditor to perform the audit to ensure that subsequent financial reporting packages are submitted timely. Views of Responsible officials and corrective actions: Documentation to perform a Single Audit of Stat FY 2023 which ended June 30, 2023 is already submitted to the auditors. They are working on control tests of the data submitted and expect to finish the Single Audit Report on March 31, 2024. Audit Status: In process of compliance.

Type of finding: Federal Award Situation: Significant deficiency; Compliance with federal regulations. Assistance Listing No: 10.576 Federal Program: Seniors Farmers’ Market Nutrition Program Name of federal agency: Department of Agriculture Covid-19 Program: No Compliance Requirements: Special Test and Provisions- Coupon, Market and CSA Program Management Prior-Year(s) Audit Finding(s): None Questioned Costs: Not determined. Condition: We noted the following exceptions regarding redeemed coupons: 1. In two of the coupons selected, the stamp was not present, therefore we could not tie in the coupon with the farmer that redeemed the coupon. 2. For one of the selected farmer files for which the coupon was redeemed, we observed that the farmer agreement was not signed by an Agency’s representative. Context: As part of our audit procedures, we selected 60 redeemed coupons and tied them with the farmer that redeemed the coupon to ascertain that AEDA complied with the Coupon, Market and CSA Program Management provisions. We noted the exceptions described above. As part of the approval of the farmer to the program, the Agency assigns a stamp number to each farmer per program year. This stamp number must be placed in the coupon when received by the farmer and is the only mechanism in place to validate that the coupon was redeemed by an authorized farmer. In two of the coupons selected, the stamp was not present, therefore we could not tie in the coupon with the farmer that redeemed the coupon. Criteria: 7 CFR Part 249.10 Coupon, market, and CSA program management states that only farmers, farmers' markets, and/or roadside stands authorized by the State agency may redeem SFMNP coupons. Only farmers authorized by the State agency or having a valid agreement with an authorized farmers' market, may redeem coupons. The State agency must design and implement a system of review of SFMNP coupons to detect errors. At a minimum, the errors the system must detect are: a missing participant signature (if such signature is required by the State agency), a missing farmer and/or market identification, and redemption by a farmer outside of the valid date. The State agency must have procedures in place to reduce the number of errors in transactions. The State agency shall identify the disposition of all SFMNP coupons as validly redeemed, lost or stolen, expired, or not matching issuance records. Validly redeemed SFMNP coupons are those that are issued to a valid participant and redeemed by an authorized farmer, farmers' market, and/or roadside stand within valid dates. 7 CFR Part 249.10 Coupon, market, and CSA program management states that The State agency shall ensure that all participating farmers' markets, roadside stands, and/or CSA programs enter into written agreements with the State agency. State agencies that authorize individual farmers shall also enter into written agreements with the individual farmers. The agreement must be signed by a representative who has legal authority to obligate the farmer, farmers' market, roadside stand, and/or CSA program. Cause: Although AEDA has a system of review of SFMNP coupons in place and internal controls procedures related to the documentation of written agreements, it was not able to trace the redeemed coupon to the authorized farmer for the two exceptions noted nor ascertain that the farmer agreement was signed by a State Agency representative for the exception noted. Effect: As per 7 CFR Part 249.10 (h), SFMNP coupons that were redeemed but cannot be traced to a valid participant or authorized farmer, farmers' market, and/or roadside stand shall be subject to claims action in accordance with § 249.20. As per CFR Part 249.20, FNS is authorized to establish claims against a State agency for unreconciled SFMNP coupons, and/or for failure to comply with the terms of duly executed CSA program contracts or agreements. When a State agency can demonstrate that all reasonable management efforts have been devoted to reconciliation and 99 percent or more of the SFMNP coupons issued, or of the eligible foods contracted for delivery by the CSA program, have been accounted for by the reconciliation process, FNS may determine that the reconciliation process has been completed to satisfaction. Auditor’s recommendation: Management should strengthen their existing system of review of SFMNP coupons in order to reduce the number of errors in transactions, where possible. Management should also continue to implement internal control procedures to ascertain continued compliance with its responsibility for the fiscal management of SFMNP-related activities. Views of Responsible officials and corrective actions: We designated and trained personnel to work with the bank statements to identify timely any voucher in which the farmer identifier is not stamped. In those cases, a copy of the voucher must be sent to the Auxiliary Market Director to proceed to identify the farmer appropriately and request from the farmer a certification attesting that he/she redeemed the voucher. Also, we instructed the Auxiliary Market Director to review all the farmer files to ensure they are completed and signed by the farmer and an Agency representative. Audit Status: In process of compliance.

Type of finding: Federal Award Situation: Significant deficiency; Compliance with federal regulations. Assistance Listing No: 10.572 and 10.576 Federal Program: WIC Farmers’ Market Nutrition Program and Senior Farmers Market Nutrition Program Name of federal agency: Department of Agriculture Covid-19 Program: No Compliance Requirements: Reporting Prior-Year(s) Audit Finding(s): 2020-002, 2019-002 Questioned Costs: Not determined. Condition: Payroll costs charged during FY 2021 and FY 2022 for the WIC Farmers’ Market Nutrition Program and Senior Farmers Market Nutrition Program were allocated at various rates. A cost allocation plan supporting such rates was not submitted for audit review. Context: Payroll costs were charged as follows: Program Report Name Report Year Payroll cost charged Cost Allocation Method WIC Farmers Market Nutrition Program Form FNS-683B WIC Farmers’ Market Nutrition Program Annual Financial and Program Data Report 2021 $44,666 For the months of January through August 2021, and December 2021 payroll charged to the program consisted of 25% and 20% of the gross salary and fringe benefits paid to program employees. For the months of September through November 2021 a 30% rate was used. WIC Farmers Market Nutrition Program Form FNS-683B WIC Farmers’ Market Nutrition Program Annual Financial and Program Data Report 2022 From: 10/2021 To: 9/2022 $49,356 During the months of January through December 2022, payroll paid to program employees were charged between the following activities: Family Market, WIC Farmer’s Market Nutrition Program and Senior Farmer Market Nutrition Program at 40%, 30%, and 30% respectively. Gross salaries and fringe benefits were multiplied by an allowable percentage of 70% or 30% to arrive at an intermediate amount called allowable payroll. Then, this amount was multiplied to 30% to arrive at the total charged payroll Context, continued: Program Report Name Report Year Payroll cost charged Cost Allocation Method Senior Farmers Market Nutrition Program Form FNS-683A Senior Farmer’s Market Nutrition Program Annual Financial and Program Data Report 2021 $44,667 For the months of January through August 2021, and December 2021 payroll charged to the program consisted of 25% and 20% of the gross salary and fringe benefits paid to program employees. For the months of September through November 2021 a 30% rate was used. Senior Farmers Market Nutrition Program Form FNS-683A Senior Farmer’s Market Nutrition Program Annual Financial and Program Data Report 2022 $42,965 During the months of January through December 2022, payroll paid to program employees were charged between the following activities: Family Market, WIC Farmer’s Market Nutrition Program and Senior Farmer Market Nutrition Program at 40%, 30%, and 30% respectively. Gross salaries and fringe benefits were multiplied by an allowable percentage of 70% or 30% to arrive at an intermediate amount called allowable payroll. Then, this amount was multiplied to 30% to arrive at the total charged payroll Criteria: As per 7 CFR part 248.12, Indirect costs are administrative costs that benefit multiple programs or activities, and cannot be identified to any one without effort disproportionate to the results achieved. In accordance with the provisions of 2 CFR part 200, subpart E and USDA implementing regulations 2 CFR part 400 and part 415, a claim for reimbursement of indirect costs shall be supported by an approved allocation plan for the determination of such costs. As Per 7 CFR part 249.12, Indirect costs are administrative costs that benefit multiple programs or activities, and cannot be identified to any one program or activity without effort disproportionate to the results achieved. In accordance with the provisions of 2 CFR part 200, subpart E and USDA implementing regulations 2 CFR part 400 and part 415, a claim for reimbursement of indirect costs shall be supported by an approved allocation plan for the determination of such costs. Cause: The State Agency is working with the Cost Allocation plan, nevertheless, is not yet finished. The State Agency is waiting for the completion of the implementation of the payroll program, that is currently in a trial stage. Effect: The State Agency is not in compliance with the recordkeeping requirements in 7 CFR part 248.23 and 249.23 that states that each State Agency must maintain full and complete records concerning FMNP and SFMNP operations. Auditor’s recommendation: The State Agency must complete their cost allocation plan that supports the rates used to account for the payroll cost charged across the Farmers Market Nutrition Programs. Views of Responsible officials and corrective actions: The Cost Allocation Plan is being drafted and will be submitted to the regulatory agency when the attendance and payroll program systems are fully implemented. Audit Status: In process of compliance.

Type of finding: Federal Award Situation: Significant deficiency; Compliance with federal regulations. Assistance Listing No: 10.572 Federal Program: WIC Farmers’ Market Nutrition Program Name of federal agency: Department of Agriculture Covid-19 Program: No Compliance Requirements: Special Test and Provisions-Coupon and Market Management Prior-Year(s) Audit Finding(s): None Questioned Costs: Not determined. Condition: In one of the coupons selected the farmer identifier, although present in the coupon, was not legible, therefore we could not tie in the coupon with the farmer that redeemed the coupon. Context: As part of our audit procedures, we selected 60 redeemed coupons and tied them with the farmer that redeemed the coupon to ascertain that AEDA complied with the Coupon and Market Management provisions. As part of the approval of the farmer to the program, the Agency assigns a stamp number to each farmer per program year. This stamp number must be placed in the coupon when received by the farmer and is the only mechanism in place to validate that the coupon was redeemed by an authorized farmer. In one of the vouchers selected, the stamp, although present in the coupon, was not legible, therefore we could not tie in the coupon with the farmer that redeemed the coupon. Criteria: 7 CFR Part 248.10 Coupon and Market Management states that only farmers, farmers' markets and roadside stands authorized by the State agency may redeem FMNP coupons. Only farmers authorized by the State agency or that have a valid agreement with an authorized farmers' market may redeem coupons. The State agency shall design and implement a system of review of FMNP coupons to detect errors. At a minimum, the errors the system must detect are a missing recipient signature, a missing farmer and/or market identification, and redemption by a farmer outside of the valid date. The State agency shall implement procedures to reduce the number of errors in transactions, where possible. The State agency shall identify the disposition of all FMNP coupons as validly redeemed, lost or stolen, expired, or not matching issuance records. Validly redeemed FMNP coupons are those that are issued to a valid recipient and redeemed by an authorized farmers/farmers' market within valid dates. Cause: Although AEDA has a system of review of FMNP coupons in place, it was not able to trace the redeemed coupon to the authorized farmer for the exception noted. Effect: As per 7 CFR Part 248.10, FMNP coupons that were redeemed but cannot be traced to a valid recipient or authorized farmer/farmers' market shall be subject to claims action in accordance with § 248.20. As per 7 CFR 248.20, FNS is authorized to establish claims against a State agency for unreconciled FMNP coupons. When a State agency can demonstrate that all reasonable management efforts have been devoted to reconciliation and 99 percent or more of the FMNP coupons issued have been accounted for by the reconciliation process, FNS may determine that the reconciliation process has been completed to satisfaction. Auditor’s recommendation: Management should strengthen their existing system of review of FMNP coupons in order to reduce the number of errors in transactions, where possible. Views of Responsible officials and corrective actions: We designed and trained personnel to work with the bank statements to identify timely any voucher in which the farmer identifier is not legible. In those cases, a copy of the voucher must be sent to the Auxiliary Market Director to proceed to identify the farmer appropriately and request from the farmer a certification attesting that he/she redeemed the voucher. Audit Status: In process of compliance.

Type of finding: Federal Award Situation: Significant deficiency; Compliance with federal regulations. Assistance Listing No: 10.572 and 10.576 Federal Program: WIC Farmers’ Market Nutrition Program and Senior Farmers Market Nutrition Program Name of federal agency: Department of Agriculture Covid-19 Program: No Compliance Requirements: Reporting Prior-Year(s) Audit Finding(s): 2020-002, 2019-002 Questioned Costs: Not determined. Condition: Payroll costs charged during FY 2021 and FY 2022 for the WIC Farmers’ Market Nutrition Program and Senior Farmers Market Nutrition Program were allocated at various rates. A cost allocation plan supporting such rates was not submitted for audit review. Context: Payroll costs were charged as follows: Program Report Name Report Year Payroll cost charged Cost Allocation Method WIC Farmers Market Nutrition Program Form FNS-683B WIC Farmers’ Market Nutrition Program Annual Financial and Program Data Report 2021 $44,666 For the months of January through August 2021, and December 2021 payroll charged to the program consisted of 25% and 20% of the gross salary and fringe benefits paid to program employees. For the months of September through November 2021 a 30% rate was used. WIC Farmers Market Nutrition Program Form FNS-683B WIC Farmers’ Market Nutrition Program Annual Financial and Program Data Report 2022 From: 10/2021 To: 9/2022 $49,356 During the months of January through December 2022, payroll paid to program employees were charged between the following activities: Family Market, WIC Farmer’s Market Nutrition Program and Senior Farmer Market Nutrition Program at 40%, 30%, and 30% respectively. Gross salaries and fringe benefits were multiplied by an allowable percentage of 70% or 30% to arrive at an intermediate amount called allowable payroll. Then, this amount was multiplied to 30% to arrive at the total charged payroll Context, continued: Program Report Name Report Year Payroll cost charged Cost Allocation Method Senior Farmers Market Nutrition Program Form FNS-683A Senior Farmer’s Market Nutrition Program Annual Financial and Program Data Report 2021 $44,667 For the months of January through August 2021, and December 2021 payroll charged to the program consisted of 25% and 20% of the gross salary and fringe benefits paid to program employees. For the months of September through November 2021 a 30% rate was used. Senior Farmers Market Nutrition Program Form FNS-683A Senior Farmer’s Market Nutrition Program Annual Financial and Program Data Report 2022 $42,965 During the months of January through December 2022, payroll paid to program employees were charged between the following activities: Family Market, WIC Farmer’s Market Nutrition Program and Senior Farmer Market Nutrition Program at 40%, 30%, and 30% respectively. Gross salaries and fringe benefits were multiplied by an allowable percentage of 70% or 30% to arrive at an intermediate amount called allowable payroll. Then, this amount was multiplied to 30% to arrive at the total charged payroll Criteria: As per 7 CFR part 248.12, Indirect costs are administrative costs that benefit multiple programs or activities, and cannot be identified to any one without effort disproportionate to the results achieved. In accordance with the provisions of 2 CFR part 200, subpart E and USDA implementing regulations 2 CFR part 400 and part 415, a claim for reimbursement of indirect costs shall be supported by an approved allocation plan for the determination of such costs. As Per 7 CFR part 249.12, Indirect costs are administrative costs that benefit multiple programs or activities, and cannot be identified to any one program or activity without effort disproportionate to the results achieved. In accordance with the provisions of 2 CFR part 200, subpart E and USDA implementing regulations 2 CFR part 400 and part 415, a claim for reimbursement of indirect costs shall be supported by an approved allocation plan for the determination of such costs. Cause: The State Agency is working with the Cost Allocation plan, nevertheless, is not yet finished. The State Agency is waiting for the completion of the implementation of the payroll program, that is currently in a trial stage. Effect: The State Agency is not in compliance with the recordkeeping requirements in 7 CFR part 248.23 and 249.23 that states that each State Agency must maintain full and complete records concerning FMNP and SFMNP operations. Auditor’s recommendation: The State Agency must complete their cost allocation plan that supports the rates used to account for the payroll cost charged across the Farmers Market Nutrition Programs. Views of Responsible officials and corrective actions: The Cost Allocation Plan is being drafted and will be submitted to the regulatory agency when the attendance and payroll program systems are fully implemented. Audit Status: In process of compliance.

Type of finding: Federal Award Situation: Significant deficiency; Compliance with federal regulations. Assistance Listing No: All Programs Compliance Requirements: Reporting Prior-Year(s) Audit Finding(s): 2020-003, 2019-003, 2018-003, 2017-008 Questioned Costs: Not determined. Condition: The Single Audit reporting package, as defined and required in 2 CRF 200.512 for fiscal year ended June 30, 2022, was not submitted timely. Context: AEDA’ Single Audit Reports have been submitted after the due date since fiscal year 2017. Criteria: As per 2 CRF 200.512, the audit, data collection form, and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report, or nine months after the end of the audit period. However, for any 2022 submissions with fiscal periods ending between January 1, 2022, and October 31, 2022, the requirement stating that single audits are due to the Federal Audit Clearinghouse 30 days after receipt of the auditor’s report(s), is waived. These audits will be considered on time if they are submitted within nine months after their fiscal period end date. Cause: AEDA has not been able to provide the necessary information for the preparation of the Single Audit Report on a timely basis. Effect: AEDA did not comply with the report submission requirement since the audit was not submitted within nine months after their fiscal period end date. Auditor’s recommendation: Management should continue to fulfill their auditee responsibilities as stated in 2 CRF 200.508 which among other things, require management to prepare appropriate financial statements and provide the auditor with access to personnel, accounts, books, records, supporting documentation, and other information as needed for the auditor to perform the audit to ensure that subsequent financial reporting packages are submitted timely. Views of Responsible officials and corrective actions: Documentation to perform a Single Audit of Stat FY 2023 which ended June 30, 2023 is already submitted to the auditors. They are working on control tests of the data submitted and expect to finish the Single Audit Report on March 31, 2024. Audit Status: In process of compliance.

Type of finding: Federal Award Situation: Significant deficiency; Compliance with federal regulations. Assistance Listing No: 10.576 Federal Program: Seniors Farmers’ Market Nutrition Program Name of federal agency: Department of Agriculture Covid-19 Program: No Compliance Requirements: Special Test and Provisions- Coupon, Market and CSA Program Management Prior-Year(s) Audit Finding(s): None Questioned Costs: Not determined. Condition: We noted the following exceptions regarding redeemed coupons: 1. In two of the coupons selected, the stamp was not present, therefore we could not tie in the coupon with the farmer that redeemed the coupon. 2. For one of the selected farmer files for which the coupon was redeemed, we observed that the farmer agreement was not signed by an Agency’s representative. Context: As part of our audit procedures, we selected 60 redeemed coupons and tied them with the farmer that redeemed the coupon to ascertain that AEDA complied with the Coupon, Market and CSA Program Management provisions. We noted the exceptions described above. As part of the approval of the farmer to the program, the Agency assigns a stamp number to each farmer per program year. This stamp number must be placed in the coupon when received by the farmer and is the only mechanism in place to validate that the coupon was redeemed by an authorized farmer. In two of the coupons selected, the stamp was not present, therefore we could not tie in the coupon with the farmer that redeemed the coupon. Criteria: 7 CFR Part 249.10 Coupon, market, and CSA program management states that only farmers, farmers' markets, and/or roadside stands authorized by the State agency may redeem SFMNP coupons. Only farmers authorized by the State agency or having a valid agreement with an authorized farmers' market, may redeem coupons. The State agency must design and implement a system of review of SFMNP coupons to detect errors. At a minimum, the errors the system must detect are: a missing participant signature (if such signature is required by the State agency), a missing farmer and/or market identification, and redemption by a farmer outside of the valid date. The State agency must have procedures in place to reduce the number of errors in transactions. The State agency shall identify the disposition of all SFMNP coupons as validly redeemed, lost or stolen, expired, or not matching issuance records. Validly redeemed SFMNP coupons are those that are issued to a valid participant and redeemed by an authorized farmer, farmers' market, and/or roadside stand within valid dates. 7 CFR Part 249.10 Coupon, market, and CSA program management states that The State agency shall ensure that all participating farmers' markets, roadside stands, and/or CSA programs enter into written agreements with the State agency. State agencies that authorize individual farmers shall also enter into written agreements with the individual farmers. The agreement must be signed by a representative who has legal authority to obligate the farmer, farmers' market, roadside stand, and/or CSA program. Cause: Although AEDA has a system of review of SFMNP coupons in place and internal controls procedures related to the documentation of written agreements, it was not able to trace the redeemed coupon to the authorized farmer for the two exceptions noted nor ascertain that the farmer agreement was signed by a State Agency representative for the exception noted. Effect: As per 7 CFR Part 249.10 (h), SFMNP coupons that were redeemed but cannot be traced to a valid participant or authorized farmer, farmers' market, and/or roadside stand shall be subject to claims action in accordance with § 249.20. As per CFR Part 249.20, FNS is authorized to establish claims against a State agency for unreconciled SFMNP coupons, and/or for failure to comply with the terms of duly executed CSA program contracts or agreements. When a State agency can demonstrate that all reasonable management efforts have been devoted to reconciliation and 99 percent or more of the SFMNP coupons issued, or of the eligible foods contracted for delivery by the CSA program, have been accounted for by the reconciliation process, FNS may determine that the reconciliation process has been completed to satisfaction. Auditor’s recommendation: Management should strengthen their existing system of review of SFMNP coupons in order to reduce the number of errors in transactions, where possible. Management should also continue to implement internal control procedures to ascertain continued compliance with its responsibility for the fiscal management of SFMNP-related activities. Views of Responsible officials and corrective actions: We designated and trained personnel to work with the bank statements to identify timely any voucher in which the farmer identifier is not stamped. In those cases, a copy of the voucher must be sent to the Auxiliary Market Director to proceed to identify the farmer appropriately and request from the farmer a certification attesting that he/she redeemed the voucher. Also, we instructed the Auxiliary Market Director to review all the farmer files to ensure they are completed and signed by the farmer and an Agency representative. Audit Status: In process of compliance.

Type of finding: Federal Award Situation: Significant deficiency; Compliance with federal regulations. Assistance Listing No: 10.572 and 10.576 Federal Program: WIC Farmers’ Market Nutrition Program and Senior Farmers Market Nutrition Program Name of federal agency: Department of Agriculture Covid-19 Program: No Compliance Requirements: Reporting Prior-Year(s) Audit Finding(s): 2020-002, 2019-002 Questioned Costs: Not determined. Condition: Payroll costs charged during FY 2021 and FY 2022 for the WIC Farmers’ Market Nutrition Program and Senior Farmers Market Nutrition Program were allocated at various rates. A cost allocation plan supporting such rates was not submitted for audit review. Context: Payroll costs were charged as follows: Program Report Name Report Year Payroll cost charged Cost Allocation Method WIC Farmers Market Nutrition Program Form FNS-683B WIC Farmers’ Market Nutrition Program Annual Financial and Program Data Report 2021 $44,666 For the months of January through August 2021, and December 2021 payroll charged to the program consisted of 25% and 20% of the gross salary and fringe benefits paid to program employees. For the months of September through November 2021 a 30% rate was used. WIC Farmers Market Nutrition Program Form FNS-683B WIC Farmers’ Market Nutrition Program Annual Financial and Program Data Report 2022 From: 10/2021 To: 9/2022 $49,356 During the months of January through December 2022, payroll paid to program employees were charged between the following activities: Family Market, WIC Farmer’s Market Nutrition Program and Senior Farmer Market Nutrition Program at 40%, 30%, and 30% respectively. Gross salaries and fringe benefits were multiplied by an allowable percentage of 70% or 30% to arrive at an intermediate amount called allowable payroll. Then, this amount was multiplied to 30% to arrive at the total charged payroll Context, continued: Program Report Name Report Year Payroll cost charged Cost Allocation Method Senior Farmers Market Nutrition Program Form FNS-683A Senior Farmer’s Market Nutrition Program Annual Financial and Program Data Report 2021 $44,667 For the months of January through August 2021, and December 2021 payroll charged to the program consisted of 25% and 20% of the gross salary and fringe benefits paid to program employees. For the months of September through November 2021 a 30% rate was used. Senior Farmers Market Nutrition Program Form FNS-683A Senior Farmer’s Market Nutrition Program Annual Financial and Program Data Report 2022 $42,965 During the months of January through December 2022, payroll paid to program employees were charged between the following activities: Family Market, WIC Farmer’s Market Nutrition Program and Senior Farmer Market Nutrition Program at 40%, 30%, and 30% respectively. Gross salaries and fringe benefits were multiplied by an allowable percentage of 70% or 30% to arrive at an intermediate amount called allowable payroll. Then, this amount was multiplied to 30% to arrive at the total charged payroll Criteria: As per 7 CFR part 248.12, Indirect costs are administrative costs that benefit multiple programs or activities, and cannot be identified to any one without effort disproportionate to the results achieved. In accordance with the provisions of 2 CFR part 200, subpart E and USDA implementing regulations 2 CFR part 400 and part 415, a claim for reimbursement of indirect costs shall be supported by an approved allocation plan for the determination of such costs. As Per 7 CFR part 249.12, Indirect costs are administrative costs that benefit multiple programs or activities, and cannot be identified to any one program or activity without effort disproportionate to the results achieved. In accordance with the provisions of 2 CFR part 200, subpart E and USDA implementing regulations 2 CFR part 400 and part 415, a claim for reimbursement of indirect costs shall be supported by an approved allocation plan for the determination of such costs. Cause: The State Agency is working with the Cost Allocation plan, nevertheless, is not yet finished. The State Agency is waiting for the completion of the implementation of the payroll program, that is currently in a trial stage. Effect: The State Agency is not in compliance with the recordkeeping requirements in 7 CFR part 248.23 and 249.23 that states that each State Agency must maintain full and complete records concerning FMNP and SFMNP operations. Auditor’s recommendation: The State Agency must complete their cost allocation plan that supports the rates used to account for the payroll cost charged across the Farmers Market Nutrition Programs. Views of Responsible officials and corrective actions: The Cost Allocation Plan is being drafted and will be submitted to the regulatory agency when the attendance and payroll program systems are fully implemented. Audit Status: In process of compliance.

Type of finding: Federal Award Situation: Significant deficiency; Compliance with federal regulations. Assistance Listing No: 10.572 Federal Program: WIC Farmers’ Market Nutrition Program Name of federal agency: Department of Agriculture Covid-19 Program: No Compliance Requirements: Special Test and Provisions-Coupon and Market Management Prior-Year(s) Audit Finding(s): None Questioned Costs: Not determined. Condition: In one of the coupons selected the farmer identifier, although present in the coupon, was not legible, therefore we could not tie in the coupon with the farmer that redeemed the coupon. Context: As part of our audit procedures, we selected 60 redeemed coupons and tied them with the farmer that redeemed the coupon to ascertain that AEDA complied with the Coupon and Market Management provisions. As part of the approval of the farmer to the program, the Agency assigns a stamp number to each farmer per program year. This stamp number must be placed in the coupon when received by the farmer and is the only mechanism in place to validate that the coupon was redeemed by an authorized farmer. In one of the vouchers selected, the stamp, although present in the coupon, was not legible, therefore we could not tie in the coupon with the farmer that redeemed the coupon. Criteria: 7 CFR Part 248.10 Coupon and Market Management states that only farmers, farmers' markets and roadside stands authorized by the State agency may redeem FMNP coupons. Only farmers authorized by the State agency or that have a valid agreement with an authorized farmers' market may redeem coupons. The State agency shall design and implement a system of review of FMNP coupons to detect errors. At a minimum, the errors the system must detect are a missing recipient signature, a missing farmer and/or market identification, and redemption by a farmer outside of the valid date. The State agency shall implement procedures to reduce the number of errors in transactions, where possible. The State agency shall identify the disposition of all FMNP coupons as validly redeemed, lost or stolen, expired, or not matching issuance records. Validly redeemed FMNP coupons are those that are issued to a valid recipient and redeemed by an authorized farmers/farmers' market within valid dates. Cause: Although AEDA has a system of review of FMNP coupons in place, it was not able to trace the redeemed coupon to the authorized farmer for the exception noted. Effect: As per 7 CFR Part 248.10, FMNP coupons that were redeemed but cannot be traced to a valid recipient or authorized farmer/farmers' market shall be subject to claims action in accordance with § 248.20. As per 7 CFR 248.20, FNS is authorized to establish claims against a State agency for unreconciled FMNP coupons. When a State agency can demonstrate that all reasonable management efforts have been devoted to reconciliation and 99 percent or more of the FMNP coupons issued have been accounted for by the reconciliation process, FNS may determine that the reconciliation process has been completed to satisfaction. Auditor’s recommendation: Management should strengthen their existing system of review of FMNP coupons in order to reduce the number of errors in transactions, where possible. Views of Responsible officials and corrective actions: We designed and trained personnel to work with the bank statements to identify timely any voucher in which the farmer identifier is not legible. In those cases, a copy of the voucher must be sent to the Auxiliary Market Director to proceed to identify the farmer appropriately and request from the farmer a certification attesting that he/she redeemed the voucher. Audit Status: In process of compliance.

Type of finding: Federal Award Situation: Significant deficiency; Compliance with federal regulations. Assistance Listing No: 10.572 and 10.576 Federal Program: WIC Farmers’ Market Nutrition Program and Senior Farmers Market Nutrition Program Name of federal agency: Department of Agriculture Covid-19 Program: No Compliance Requirements: Reporting Prior-Year(s) Audit Finding(s): 2020-002, 2019-002 Questioned Costs: Not determined. Condition: Payroll costs charged during FY 2021 and FY 2022 for the WIC Farmers’ Market Nutrition Program and Senior Farmers Market Nutrition Program were allocated at various rates. A cost allocation plan supporting such rates was not submitted for audit review. Context: Payroll costs were charged as follows: Program Report Name Report Year Payroll cost charged Cost Allocation Method WIC Farmers Market Nutrition Program Form FNS-683B WIC Farmers’ Market Nutrition Program Annual Financial and Program Data Report 2021 $44,666 For the months of January through August 2021, and December 2021 payroll charged to the program consisted of 25% and 20% of the gross salary and fringe benefits paid to program employees. For the months of September through November 2021 a 30% rate was used. WIC Farmers Market Nutrition Program Form FNS-683B WIC Farmers’ Market Nutrition Program Annual Financial and Program Data Report 2022 From: 10/2021 To: 9/2022 $49,356 During the months of January through December 2022, payroll paid to program employees were charged between the following activities: Family Market, WIC Farmer’s Market Nutrition Program and Senior Farmer Market Nutrition Program at 40%, 30%, and 30% respectively. Gross salaries and fringe benefits were multiplied by an allowable percentage of 70% or 30% to arrive at an intermediate amount called allowable payroll. Then, this amount was multiplied to 30% to arrive at the total charged payroll Context, continued: Program Report Name Report Year Payroll cost charged Cost Allocation Method Senior Farmers Market Nutrition Program Form FNS-683A Senior Farmer’s Market Nutrition Program Annual Financial and Program Data Report 2021 $44,667 For the months of January through August 2021, and December 2021 payroll charged to the program consisted of 25% and 20% of the gross salary and fringe benefits paid to program employees. For the months of September through November 2021 a 30% rate was used. Senior Farmers Market Nutrition Program Form FNS-683A Senior Farmer’s Market Nutrition Program Annual Financial and Program Data Report 2022 $42,965 During the months of January through December 2022, payroll paid to program employees were charged between the following activities: Family Market, WIC Farmer’s Market Nutrition Program and Senior Farmer Market Nutrition Program at 40%, 30%, and 30% respectively. Gross salaries and fringe benefits were multiplied by an allowable percentage of 70% or 30% to arrive at an intermediate amount called allowable payroll. Then, this amount was multiplied to 30% to arrive at the total charged payroll Criteria: As per 7 CFR part 248.12, Indirect costs are administrative costs that benefit multiple programs or activities, and cannot be identified to any one without effort disproportionate to the results achieved. In accordance with the provisions of 2 CFR part 200, subpart E and USDA implementing regulations 2 CFR part 400 and part 415, a claim for reimbursement of indirect costs shall be supported by an approved allocation plan for the determination of such costs. As Per 7 CFR part 249.12, Indirect costs are administrative costs that benefit multiple programs or activities, and cannot be identified to any one program or activity without effort disproportionate to the results achieved. In accordance with the provisions of 2 CFR part 200, subpart E and USDA implementing regulations 2 CFR part 400 and part 415, a claim for reimbursement of indirect costs shall be supported by an approved allocation plan for the determination of such costs. Cause: The State Agency is working with the Cost Allocation plan, nevertheless, is not yet finished. The State Agency is waiting for the completion of the implementation of the payroll program, that is currently in a trial stage. Effect: The State Agency is not in compliance with the recordkeeping requirements in 7 CFR part 248.23 and 249.23 that states that each State Agency must maintain full and complete records concerning FMNP and SFMNP operations. Auditor’s recommendation: The State Agency must complete their cost allocation plan that supports the rates used to account for the payroll cost charged across the Farmers Market Nutrition Programs. Views of Responsible officials and corrective actions: The Cost Allocation Plan is being drafted and will be submitted to the regulatory agency when the attendance and payroll program systems are fully implemented. Audit Status: In process of compliance.