Finding 1090274 (2022-003)

Temporary Assistance for Needy Families; ALN 93.558; U.S. Department of Health and Human Services Finding Type: Material Weakness and Material Noncompliance Condition: There were no formal, documented federal policies and procedures in place for December 31, 2022, 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 is in the process of implementing documented federal policies and procedures.