Finding Text
Information on the Federal Program: Assistance Listing Number 10.568—Food Distribution Cluster; Emergency Food Assistance Program (Food Commodities). Pass-Through Entity: Los Angeles Regional Foodbank. Compliance Requirements: Eligibility. Type of Finding: Material Noncompliance.
Criteria: According to the agreement between the Emergency Recipient Agency (ERA) and NVCS, individuals receiving commodities under The Emergency Food Assistance Program (TEFAP) are required to self‐certify that they meet the applicable income eligibility guidelines. This is accomplished by signing the TEFAP Household Distribution Sign‐In Sheet (Form EFA‐7), as specified in the contract. This contractual requirement is consistent with 7 CFR § 251.5(b), which requires ERAs to certify household eligibility using income criteria established by the state agency and approved by the Food and Nutrition Service (FNS) in accordance with 7 CFR § 251.6(a). Additionally, guidance provided by LARFB, the pass‐through entity, allows for limited exceptions through a ʺVolunteer Proxyʺ process. Under this provision, staff or volunteers may sign on behalf of recipients when noted explicitly as “Volunteer Proxy: [Name]” on the EFA‐7 form.
Condition: During our review of the EFA-7 Forms for the year ended June 30, 2024, we noted that recipients did not personally sign the sign‐in sheets. Instead, a staff member signed each line item, and while recipient names were documented, the required “Volunteer Proxy: [Name]” designation was not included. Management confirmed that this method was used consistently across distributions but acknowledged that the proper proxy designation was omitted.
Cause: NVCS misunderstood the requirement that each TEFAP recipient must personally self-certify eligibility by signing the EFA-7 form during commodity distribution. Staff believed documenting recipient information via food pickup receipts was sufficient. This misunderstanding, coupled with the absence of formal internal procedures to enforce compliance, resulted in the failure to obtain required signatures.
Effect or Potential Effect: The absence of self that TEFAP distributions were made to individuals without verifiable eligibility documentation. This documentation gap may limit the pass‐through entity’s and the organization’s ability to demonstrate compliance with federal eligibility rules, potentially affecting program oversight or future funding.
Questioned Costs: None
Context: We reviewed a sample of EFA-7 Forms representing 6 distributions out of 52 total distributions during the audit period. In 100% of the sampled distributions, recipient names were recorded, but no forms included personal signatures or proxy designations, indicating a systemic issue of incomplete documentation..
Repeat Finding: No — This is NVCS's first Single Audit.
Recommendation: We recommend that NVCS fully implement the proxy signature process as permitted by LARFB by clearly indicating “Volunteer Proxy: [Name]” on the EFA‐7 sign‐in sheets when recipients are unable to sign. Additionally, staff should be trained on TEFAP documentation requirements, and management should adopt internal monitoring procedures to ensure compliance across all distributions.
Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding. NVCS was followed guidance received from the pass‐through entity but did not fully implement the required proxy documentation format. Management will revise procedures to ensure that the “Volunteer Proxy: [Name]” designation is clearly included where applicable and will provide training to distribution staff. Internal monitoring will be implemented to ensure future compliance. The corrective action is expected to be fully implemented by March 1, 2025.