Finding 1174087 (2025-001)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-02-18
Audit: 387744
Organization: Mid-South Food Bank (TN)

AI Summary

  • Core Issue: Lack of formal approval for manual inventory adjustments increases the risk of inaccurate financial reporting.
  • Impacted Requirements: Internal controls for safeguarding assets and maintaining accurate records for USDA food distributions are not being met.
  • Recommended Follow-Up: Implement formal controls, including supervisory approval for adjustments, monthly reconciliations, and proper documentation retention.

Finding Text

Criteria: Management is responsible for designing and maintaining internal controls that provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with U.S. GAAP and that assets, including inventory, are safeguarded from loss or misuse. Additionally, organizations receiving USDA foods must maintain accurate records of receipts, distributions, and adjustments to account for the disposition of all commodities. Condition and Context: We identified that manual positive and negative inventory adjustments were recorded in the general ledger and CERES inventory system for donated inventory as well as Tennessee and Mississippi USDA programs during the fiscal year. The Food Bank has no formal approval process for these manual adjustments. Cause: The weakness results from the absence of designed and implemented controls to ensure that manual adjustments are reviewed, supported, and approved. Effect: The lack of preventive and detective controls increases the risk that inventory balances may be misstated during the year and that errors or irregularities could go undetected until year-end. While the Food Bank performs an annual physical inventory that trues up balances, this end-of-year process does not mitigate the risk of material misstatement throughout the reporting period. The unrestricted ability to post manual entries without documentation presents an ongoing risk of inaccurate financial reporting. Questioned Costs: None noted. Repeat Finding: No Recommendation: We recommend that management implement formal controls over manual inventory adjustments and reconciliations, including: • Requiring supervisory review and approval for all manual inventory adjustments; • Performing monthly reconciliations of inventory activity to supporting documentation and shipment records; • Ensuring all distributions are processed through the normal invoicing workflow rather than through post-period adjustments; and • Retaining documentation that clearly explains the nature and reason for each adjustment. View of Responsible Official: See Management’s Corrective Action Plan.

Corrective Action Plan

Management concurs with Audit Finding 2025-001 and will implement enhanced internal controls over inventory adjustments to ensure accurate accounting for the receipt, distribution, and disposition of all USDA commodities in compliance with Special Tests and Provisions requirements. Management will implement the following corrective actions: 1. Formal Approval and Authorization of Inventory Adjustments Management will establish a formal policy requiring documented supervisory review and approval for all manual positive and negative inventory adjustments recorded in the general ledger and the CERES inventory system. Approval will be obtained prior to posting adjustments, and access to record adjustments will be restricted to authorized personnel. 2. Standardized Documentation for Adjustments Each inventory adjustment will be supported by standardized documentation clearly explaining the nature, reason, and calculation of the adjustment, along with applicable supporting records (e.g., receiving documents, distribution records, shortage documentation). All documentation will be retained in accordance with USDA record retention requirements. 3. Reconciliation of Inventory Activity Management will implement a periodic (at least monthly) reconciliation of inventory receipts, distributions, and adjustments to CERES and the general ledger. Reconciling items will be investigated, resolved, and documented timely. 4. Monitoring of USDA Program Inventory Management will perform periodic reviews of inventory activity related to donated inventory and Tennessee and Mississippi USDA programs to ensure that adjustments are appropriate, approved, and accurately recorded. 5. Training and Ongoing Oversight Management will provide targeted training to staff involved in inventory and accounting processes regarding USDA Special Tests and Provisions requirements and the new approval and documentation procedures. Management will monitor compliance with these controls to ensure they are operating effectively. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)

Categories

Equipment & Real Property Management Reporting School Nutrition Programs

Other Findings in this Audit

  • 1174071 2025-001
    Material Weakness Repeat
  • 1174072 2025-002
    Material Weakness Repeat
  • 1174073 2025-003
    Material Weakness Repeat
  • 1174074 2025-004
    Material Weakness Repeat
  • 1174075 2025-001
    Material Weakness Repeat
  • 1174076 2025-002
    Material Weakness Repeat
  • 1174077 2025-003
    Material Weakness Repeat
  • 1174078 2025-004
    Material Weakness Repeat
  • 1174079 2025-001
    Material Weakness Repeat
  • 1174080 2025-002
    Material Weakness Repeat
  • 1174081 2025-003
    Material Weakness Repeat
  • 1174082 2025-004
    Material Weakness Repeat
  • 1174083 2025-001
    Material Weakness Repeat
  • 1174084 2025-002
    Material Weakness Repeat
  • 1174085 2025-003
    Material Weakness Repeat
  • 1174086 2025-004
    Material Weakness Repeat
  • 1174088 2025-002
    Material Weakness Repeat
  • 1174089 2025-003
    Material Weakness Repeat
  • 1174090 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $8.62M
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $1.55M
10.182 PANDEMIC RELIEF ACTIVITIES: LOCAL FOOD PURCHASE AGREEMENTS WITH STATES, TRIBES, AND LOCAL GOVERNMENTS $733,293
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $150,939
10.178 TRADE MITIGATION PROGRAM ELIGIBLE RECIPIENT AGENCY OPERATIONAL FUNDS $140,471
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $74,518
97.024 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $33,335
10.187 THE EMERGENCY FOOD ASSISTANCE PROGRAM (TEFAP) COMMODITY CREDIT CORPORATION ELIGIBLE RECIPIENT FUNDS $13,049
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $10,000