Finding Text
Finding number: 2024-002 - Lack of Operating Effectiveness on Internal Control Over Compliance
for Food Distributions
AL number: 10.568, 10.569, 10.565
AL title: Emergency Food Assistance Program – Food Distribution Cluster
Compliance requirement:
Name of federal agency:
Name of pass-through entity:
Special Tests and Provisions
U.S. Department of Agriculture Illinois Department of Human 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 special tests and provisions. A proper internal control system
requires that documentation supporting compliance with program requirements, including inventory
distributions, be accurate, complete, and prepared in a timely manner to prevent errors or
misstatements.
SECTION III - SUMMARY OF FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (continued)
Condition: During the audit, it was identified that an invoice signed by the partner agency
indicated an incorrect gross weight compared to inventory disbursed per the inventory system.
However, the actual inventory disbursed differed due to items being unavailable or insufficient
during packing. Although the disbursed amount was accurately reflected in the accounting system and
subsequent reports, and an email was sent to the partner agency confirming the actual disbursement,
the signed packing list/invoice provided at the time of delivery was not updated to reflect the
actual disbursed inventory.
Cause: The discrepancy occurred due to significant turnover in the warehouse and the
absence of specific Standard Operating Procedures (SOPs) for the packing and distribution process.
Packing lists were printed the night before delivery, and adjustments made during packing the
following morning were not reflected in updated packing lists due to timing constraints.
Possible effect: The signed packing list/invoice did not accurately reflect the actual
inventory disbursed, indicating a control deficiency in the process for ensuring the accuracy of
documentation for inventory distributions.
Questioned cost: None
Recommendation: The Organization should develop and implement formal SOPs for inventory packing
and distribution processes. These SOPs should include procedures for updating and reconciling
packing lists with actual disbursements to ensure that all documentation accurately reflects the
distributed inventory. Additionally, staff training should be conducted to ensure adherence to
these procedures.
Views of responsible officials:
Corrective Action Plan: Food distribution invoice signed by one (1) partner agency did not agree to
the actual weight disbursed.
We have taken action to address this issue, and it has already been implemented. A new Chief
Operating Officer along with several warehouse employees were hired to ensure that proper staffing
was maintained in the process. Management has also developed new Standard Operating Procedures
(SOPs) and training programs for warehouse staff to ensure accurate documentation and compliance
moving forward. This allows for the packing lists to be printed and packing to occur well in
advance to allow for adjustments to be made in time to accurately reflect the amounts disbursed.
The new SOPs also include that partner agencies have at least 24 hours to contact the Organization
for any issues with the distribution and the Organization will update documentation and/or correct
the order to reflect the documentation. Two positions have been staffed: Inventory Control and
Quality Control part of their role is to make sure the pick ticket matches the pick order and then
reconcile against the invoice at the time of posting.
Name of Responsible Person: Meredith Knopp, Chief Executive Officer Anticipated Completion Date:
Implemented in December 31, 2024