Finding 1157179 (2024-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 369485
Organization: The Just One Project (NV)

AI Summary

  • Core Issue: The Organization failed to retain necessary documentation to verify household eligibility for the Commodity Supplemental Food Program.
  • Impacted Requirements: This finding violates 7 CFR section 251.5, which mandates proper certification of income eligibility for participants.
  • Recommended Follow-Up: Implement written policies to ensure documentation is collected and retained for all participants, addressing the repeat finding from the previous audit.

Finding Text

ALN and Title: 10.565 – Commodity Supplemental Food Program Cluster Name: Total Food Distribution Cluster Federal Agency: U.S. Department of Agriculture Passthrough Entity: State of Nevada Department of Agriculture Type of Finding: Significant Deficiency Criteria: Per 7 CFR section 251.5 (referenced in the Compliance Supplement of the Uniform Guidance), commodities received by the Organization requires certification of households eligible to receive these commodities for consumption by applying income eligibility criteria established by the state agency (Nevada Department of Agriculture, in this case). Condition: During testing procedures over eligibility, it was noted that the Organization had not retained supporting documentation to verify certification was complete and accurate. Cause: The Organization was unable to establish consistent controls over certification of income eligibility due to high staff turnover. Effect: Documentation to determine eligibility was not retained for every participant during the fiscal year. Questioned Costs: Unknown. Identification of a repeat finding: This is a repeat finding from the immediate previous audit, 2023-001. Context: The Organization was missing verifiable documentation for eligible income requirements for 4 out of the 25 participants tested for the single audit. Recommendation: The Organization should develop and implement written policies and procedures that meet the eligibility requirements of the Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards. This would include a review of applications to ensure participants have confirmed in a verifiable way that they meet the income eligibility criteria to receive benefits. Documentation should be retained so testing procedures by outside auditors can be performed. Views of responsible Officials: Management agrees with this recommendation. See auditee prepared corrective action plan for details.

Corrective Action Plan

The Just One Project's CSFP team will maintain a filing system organized by service site, alphabetical client name, and month and year of registration. The team will also utilize the Salesforce system to track registered clients, recertification dates, and services provided each day. Effective immediately, designated CSFP staff will visit all active distribution sites each business day to collect new registration and recertification forms, cross-check them and previously filed forms against the day's Salesforce distribution list, and file new forms in the designated system. This will ensure every client record is complete and current. In addition, the team will conduct an internal audit at least annually to confirm that all participant files contain required documents and certifications, promptly address any deficiencies, and document corrective steps. Staff will also receive periodic refresher training to reinforce record-keeping standards and sustain compliance.

Categories

Allowable Costs / Cost Principles Eligibility Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.569 Emergency Food Assistance Program (food Commodities) $4.00M
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $835,423
14.241 Housing Opportunities for Persons with Aids $704,435
21.027 Coronavirus State and Local Fiscal Recovery Funds $373,522
14.267 Continuum of Care Program $301,626
10.565 Commodity Supplemental Food Program $225,719
97.024 Emergency Food and Shelter National Board Program $125,519
94.002 Americorps Seniors Retired and Senior Volunteer Program (rsvp) 94.002 $85,761
93.053 Nutrition Services Incentive Program $34,473
14.218 Community Development Block Grants/entitlement Grants $10,750
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $7,349