Finding 1163629 (2024-002)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
$1
Year
2024
Accepted
2025-12-08

AI Summary

  • Core Issue: The Organization failed to keep proper records for federal expenditures, leading to potential misuse of funds.
  • Impacted Requirements: Noncompliance with 2 CFR Sections 200.334 and 200.403 regarding record retention and allowable costs.
  • Recommended Follow-Up: Improve internal controls for recordkeeping and documentation, and establish ongoing monitoring to prevent future issues.

Finding Text

Finding 2024-002: Failure to Follow Recordkeeping Requirements for Expenditures (Material Weakness) Federal Agency: United States Department of Agriculture Federal Program Name: COVID-19 - Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments Assistance Listing Number: 10.182 Pass-Through Entity: State of Florida Department of Agriculture Compliance Requirement: Allowable Costs/Cost Principles Criteria: 2 CFR Section 200.334, requires recipients and subrecipients to retain all Federal award records for three years from the date of submission of their final financial reports (quarterly or annually). Records include, but are not limited to, financial records, supporting documentation, and statistical information. Additionally, 2 CFR Section 200.403, requires that costs must meet certain criteria to be allowable under federal awards, specifically 2 CFR Section 200.403(g), requires adequate documentation of those costs. Condition: During our testing, the Organization was unable to provide appropriate supporting documentation that evidenced a proper activity was conducted using federal funding, and further we could not determine if the costs incurred were allowable. Additionally, we noted that the Organization did not establish adequate internal controls to ensure supporting documentation was maintained to evidence that compliance was achieved. Cause: The OrganizationÂ’s internal controls were not effectively designed over recordkeeping of food purchases. Known Questioned Costs: $166,610 Context: The total sample size was 100 items of expense, which was determined to be a statistically valid sample. 10 out of the 100 items tested were not supported by appropriate documentation. 5 out of 100 items tested included freight costs that were included in the food costs. Freight should have been separated and classified as an administrative cost. These items resulted in the questioned costs calculated above and the noncompliance reported. The total population of expenditures charged to the federal program, from which our sample was selected, was $14,401,876. Effect: Federal funds may have been used for unallowable costs and therefore the purpose of the award may not have been met. Overall, this results in noncompliance with federal award requirements. Recommendation: We recommend the Organization evaluate its internal controls over allowable costs, recordkeeping and recording of federal expenditures and implement internal control procedures to ensure documentation is appropriately maintained for the required timeframe. Ongoing monitoring of the controls designed should be established to ensure future failures are minimized.

Corrective Action Plan

Management Response: Feeding South Florida complied with LFPA contract provisions for food purchases by meeting and invoicing the required food purchase minimum. Freight was an allowable cost for the contract. Despite miscategorizing 5 freight invoices, Feeding South Florida complied with the LFPA contract for freight by meeting and invoicing the total amount allowable for freight. To ensure ongoing compliance, we established and implemented a comprehensive Standard Operating Procedure (SOP) for all contracts and grants, including the LFPA program, which has been consistently followed since LFPA Plus began. To strengthen oversight and enhance audit readiness, administrative responsibility for this contract has transitioned from the Grants Department to the Finance Department. This restructuring reinforces our compliance framework, improves operational support, and embeds stronger accountability measures across all organizational levels and throughout our region.

Categories

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Programs in Audit

ALN Program Name Expenditures
10.182 PANDEMIC RELIEF ACTIVITIES: LOCAL FOOD PURCHASE AGREEMENTS WITH STATES, TRIBES, AND LOCAL GOVERNMENTS $14.40M
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $2.32M
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $898,220
10.565 COMMODITY SUPPLEMENTAL FOOD PROGRAM $318,042
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $198,606
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $160,496
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $113,080
10.558 CHILD AND ADULT CARE FOOD PROGRAM $61,200
97.024 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $30,930
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $3,782