Finding 1175316 (2025-002)

Material Weakness Repeat Finding

Requirement

Questioned Costs

Year

2025

Accepted

2026-02-25

Audit: 389029

Organization: Second Harvest Northern Lakes Food Bank (MN)

Auditor: ABDO LLP

AI Summary

Core Issue: Missing vendor selection form for a purchase indicates noncompliance with procurement requirements.
Impacted Requirements: Violates Uniform Guidance (2 CFR 200.320) and the Organization’s procurement policy regarding competitive quotations.
Recommended Follow-Up: Update procurement procedures to align with Uniform Guidance and ensure compliance moving forward.

Finding Text

Coronavirus State and Local Fiscal Recovery Funds: Noncompliance over Procurement Condition: During our testing of procurement requirements, we noted that for one of the purchases selected there was no vendor selection form. The vendor selection form identifies the price and method selected. Without the form, the procurement documentation does not exist. Criteria: Uniform Guidance (2 CFR 200.320) and the Organization’s procurement policy require that micro-purchases may be awarded without soliciting competitive quotations if the Organization considers the price to be reasonable and small purchases require price or rate quotations to be obtained from an adequate number of qualified sources. Cause: The exception was due to a breakdown in the Organization’s procedures to ensure that all procurements are in accordance with Uniform Guidance. Effect: Improper procurement procedures can result in actions taken by oversight agencies which could impact future funding. Context: The population subject to procurement requirements included three procurements. The sample size of two procurements was determined. Recommendation: We recommend that the Organization review and update its procedures to ensure that all procurements are in accordance with the Uniform Guidance and its procurement policy. Views of Responsible Officials: Management agrees with the finding.

Corrective Action Plan

Corrective Action: SHN will develop a comprehensive Federal Grants Management Policy Manual, including procurement-related procedures that fully align with the requirements of Uniform Guidance (2 CFR 200.320). The draft manual and related procedures will be reviewed by an external Federal Grants Management Specialist to ensure accuracy and compliance. As of January 2026, SHN is continuing to refine and update its procurement procedures to ensure full compliance with Uniform Guidance and alignment across all federal grant–related purchasing activities. This will be completed by June 30, 2026. Proposed completion date: Management will develop procedures for Board of Directors approval in June 2026.

Other Findings in this Audit

1175312 2025-001

Material Weakness Repeat
1175313 2025-001

Material Weakness Repeat
1175314 2025-001

Material Weakness Repeat
1175315 2025-002

Material Weakness Repeat
1175317 2025-003

Material Weakness Repeat
1175318 2025-003

Material Weakness Repeat
1175319 2025-004

Material Weakness Repeat
1175320 2025-004

Material Weakness Repeat

Programs in Audit

ALN	Program Name	Expenditures
10.569	EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES)	$4.03M
10.565	COMMODITY SUPPLEMENTAL FOOD PROGRAM	$1.06M
10.568	EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS)	$858,628
21.027	CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS	$100,735