Finding Text
Finding number: 2024-003
AL number: 10.568, 10.569, 10.565
AL title: Emergency Food Assistance Program and Commodity Supplemental Food Program – Food
Distribution Cluster
Compliance requirement:
Name of federal agency:
Name of pass-through entity:
Eligibility and Activities Allowed
U.S. Department of Agriculture
Illinois Department of Human Services and Missouri Department of Social Services
Type of finding: Significant Deficiency in Internal Control over Compliance of Major Programs
Criteria: St. Louis Area Food Bank, Inc. is responsible for implementing and maintaining a
proper internal control system over eligibility and activities allowed. Internal controls over
compliance require that agreements and documentation be executed in a timely manner to maintain
compliance with program requirements and ensure accountability.
Condition: During the audit, it was discovered that due to significant staff turnover during
the year, certain required agreements for the fiscal year period (July 1, 2023 – June 30, 2024)
with partner agencies were not signed until late fiscal year 2024 or fiscal year 2025. This delay
in execution of required agreements represents a control deficiency over documentation
requirements.
Cause: The delay in executing required agreements was attributed to staff turnover, which
resulted in lapses in the process and oversight of ensuring timely completion and signing of
documentation.
Possible effect: Failure to execute required agreements in a timely manner increases the risk
of non-compliance with eligibility and activities allowed requirements and undermines the
effectiveness of internal controls over compliance.
Questioned cost: None
Recommendation: The Organization should implement procedures to mitigate the impact of staff
turnover, including cross-training and clear documentation of roles and responsibilities
related to the execution of required agreements. Management should establish a tracking system to
monitor agreement completion and ensure timely follow-up. Additionally, management should provide
periodic training to relevant staff to reinforce the importance of timely compliance with
documentation requirements.
SECTION III - SUMMARY OF FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (continued)
Views of responsible officials:
Corrective Action Plan: Single Audit partner agreements for fiscal year 2024 (July 1, 2023 – June
30, 2024) with five (5) partner agencies were signed in June
2024 and November 2024.
Management notes that as of year-end and final fieldwork, personnel are now in place who understand
the importance of maintaining and completing required documentation, including annual and bi-annual
agreements. Management will implement additional measures, such as improved tracking systems and
staff training, to prevent future delays in the execution of required annual and bi- annual
agreements. Management currently reconciles A133 documents to agency partners. In addition, the
management team is ensuring documents are signed and stored in an electronic document signature
platform i.e DocuSign. Access to this platform will be available to all key staff for utilization
and verification. Tracking is also documented within a separate excel spreadsheet and reconciled
back to the electronic signature database. A Standard Operating Procedure has been created and
implemented.
Name of Responsible Person: Meredith Knopp, Chief Executive Officer Anticipated Completion Date:
December 31, 2024