Finding 1170406 (2025-003)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-01-23
Audit: 383563
Organization: Great Plains Food Bank (ND)
Auditor: EIDE BAILLY

AI Summary

  • Core Issue: There are significant deficiencies in internal controls over eligibility determinations for federal awards, leading to incomplete and inaccurate documentation.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a) is lacking, as timely and accurate eligibility reviews were not consistently performed.
  • Recommended Follow-Up: Management should enhance internal control procedures to ensure all eligibility reviews are properly documented and consider relevant timelines for applications.

Finding Text

U.S. Department of Agriculture Passed Through the North Dakota Department of Public Instruction and the Minnesota Department of Human Services Federal Financial Assistance Listing # 10.568 All Awards Federal Financial Assistance Listing # 10.569 All Awards Food Distribution Cluster Eligibility Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. This includes a process to ensure proper completion of all tracking forms and documentation, including documented reviews in relation to eligibility. Condition – During our review of the eligibility determinations, it was identified that there were various instances where applications or other eligibility determinations and reviews were not completed timely or accurately. The files were missing the documented processes or were completed after the prior form’s expiration dates. Cause – Due to oversight by management, all forms were not completed and documented within participant files. This was largely due to differences in fiscal years, calendar years, and terms of the applications and certifications not being appropriately considered when completing and monitoring the various eligibility documents. Effect – The Organization’s internal control process was not appropriately enforced and monitored, resulting in lack of timely documentation of eligibility determination. However, it is noted that the agencies were subsequently determined to be eligible for the program. Questioned Costs – $29,692 Context/Sampling – A nonstatistical sample of 32 participating agencies within TEFAP who received $2,061,190 in food commodities, out of a population of 151 agencies receiving food commodities totaling $5,958,935, were selected for eligibility testing. 4 out of the 32 eligibility determinations tested had an error, with 4 of those resulting in questioned costs, as reported above. Repeat Finding from Prior Year(s) – Yes, Finding 2024-003. Recommendation – Management should review internal control procedures to ensure all eligibility determination reviews are documented and retained in the file and consideration is appropriately given to fiscal year, calendar year, and application terms. Views of Responsible Officials – Management agrees with the finding.

Corrective Action Plan

U.S. Department of Agriculture Passed Through the North Dakota Department of Public Instruction and the Minnesota Department of Human Services Federal Financial Assistance Listing # 10.568 All Awards Federal Financial Assistance Listing # 10.569 All Awards Food Distribution Cluster Finding Summary: As part of the audit done by Eide Bailly LLP, a lack of internal controls were identified in eligibility determinations and reviews for The Emergency Food Assistance Programs. Responsible Individuals: Kate Molbert, COO David Stachon, CFO Corrective Action Plan: The GPFB will ensure all documents for TEFAP programs have proper signatures by necessary parties going forward. An electronic signature process has been implemented to make the dissemination, review and storage of this process easier. Also, additional staffing has been hired to manage this process in the form of a Programs and Operations Compliance Manager with substantial compliance experience. Anticipated Completion Date: Immediate

Categories

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility Significant Deficiency

Other Findings in this Audit

  • 1170395 2025-004
    Material Weakness Repeat
  • 1170396 2025-004
    Material Weakness Repeat
  • 1170397 2025-004
    Material Weakness Repeat
  • 1170398 2025-004
    Material Weakness Repeat
  • 1170399 2025-004
    Material Weakness Repeat
  • 1170400 2025-004
    Material Weakness Repeat
  • 1170401 2025-003
    Material Weakness Repeat
  • 1170402 2025-003
    Material Weakness Repeat
  • 1170403 2025-003
    Material Weakness Repeat
  • 1170404 2025-003
    Material Weakness Repeat
  • 1170405 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $5.54M
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $1.99M
10.565 COMMODITY SUPPLEMENTAL FOOD PROGRAM $541,252
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $230,014
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $162,622
10.182 PANDEMIC RELIEF ACTIVITIES: LOCAL FOOD PURCHASE AGREEMENTS WITH STATES, TRIBES, AND LOCAL GOVERNMENTS $29,586
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $29,287