Finding 1176662 (2024-002)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2026-03-05

AI Summary

  • Core Issue: The organization lacks adequate documentation for food distributions, leading to an incomplete audit trail.
  • Impacted Requirements: Compliance with internal policies and federal grant requirements (Uniform Guidance 2 CFR §200.302 & §200.303) is at risk due to insufficient record-keeping.
  • Recommended Follow-Up: Implement formal procedures to track all food distributions and on-site meal preparation, ensuring all records are retained and reconciled with monthly reports.

Finding Text

Finding Reference Number: 2024-002 Reportable finding considered a significant deficiency - Inadequate support for distribution of donated food Title and CFDA Number of Federal Program: Emergency Food Assistance Program: 10.568 & 10.569 Federal award numbers & periods: 22-MOU-00108 23/24. 10/1/2023 - 9/30/2024 22-MOU-00108 24/25. 10/1/2024 - 9/30/2025 Type of Finding: Financial Statement and Federal Award Finding Finding Resolution Status: In Process Identification of Repeat Finding and Finding Reference Number: This is not a repeat finding Criteria: Organizations are required to maintain adequate documentation and an audit trail for all food distributions, including goods sent to distribution sites and goods used for on-site meal preparation, in accordance with sound internal control practices and applicable grant requirements (e.g., Uniform Guidance 2 CFR §200.302 – Financial Management and §200.303 – Internal Controls). Statement of Condition: During the audit, Food Bank Distribution Reports were provided showing goods sent to three locations, including recipient sign-offs, stating they received the food. Each location tracks food received and distributed to individuals. Leftover food is sent to various nonprofits to assist with distribution, if any. However, documentation for goods that were received and not distributed, at these three locations, could not be produced for review as an audit trail for who received and distributed leftover food. Additionally, Congregate Aggregate Feeding Reports, which track goods used for on-site meal preparation, and subsequent distribution, were also not available for review as they were not kept on file. The Organization lacked distribution documentation to support their monthly Distribution Report for goods distributed resulting in an incomplete audit trail. Cause: The Organization did not have formalized procedures or controls to ensure that all food distributions and on-site meal preparation activities were consistently documented and retained. Tracking was handled internally without standardized reporting requirements, resulting in incomplete records. Effect or Potential Effect: The absence of complete supporting documentation limits the Organization’s ability to demonstrate compliance with internal policies and donor requirements. It increases the risk of misstatement, misappropriation of goods, and potential noncompliance with grant or regulatory requirements. Questioned Costs: There are no questioned costs associated with this finding. Context: During our testing of food distribution documentation, we selected Food Bank Distribution Reports from three distribution locations for the audit period. For each location, we reviewed documentation supporting goods received, goods distributed, and any goods remaining at the end of the distribution cycle. While signed recipient logs were available to support goods initially received at the locations, supporting documentation for goods that were received but not distributed—including records identifying where leftover food was subsequently sent—was not available for any of the three locations reviewed. Additionally, for onsite meal preparation activities, we requested Congregate Aggregate Feeding Reports used to track the quantities of goods prepared and served; however, the Organization did not retain these reports for the period under audit. As a result, none of the sampled items related to meal preparation activities had supporting documentation available for review. Recommendation: We recommend that management implement and enforce policies to ensure that all food distributions, including on-site meal preparation and any goods not distributed separately, are properly tracked and supported by documentation. This should include maintaining Congregate Aggregate Feeding Reports, retaining all distribution records and reconciling them to the Monthly Distribution Report, establishing procedures to ensure discarded goods are documented appropriately. These steps will strengthen internal controls and provide a clear audit trail for all commodities. Auditors’ Summary of the Auditee’s Comments on the Findings and Recommendations: See Corrective Action Plan

Corrective Action Plan

Corrective Action Plan - Audit Finding 2024-002 Reportable finding considered a significant deficiency - Inadequate support for distribution of donated food 1. Documentation Procedures The Organization has updated its policies in 2025 to ensure all food distributions—including goods received, distributed, used for on site meal preparation, and leftover items transferred to partner nonprofits—are supported by appropriate documentation. A standardized set of templates will be used to record: • Distribution logs at each location • Congregate Aggregate Feeding Reports • Documentation of leftover or transferred goods All documentation will be retained in a centralized repository accessible to program and compliance staff. ________________________________________ 2. Distribution Tracking Controls The Organization has implemented strengthened controls to ensure accurate and complete tracking of all food commodities. These controls include: • Required completion of distribution logs at all partner locations • Mandatory retention of Congregate Aggregate Feeding Reports • Reconciliation of monthly distribution activity to the Monthly Distribution Report • Documentation of discarded or transferred goods A compliance checklist is being developed to verify that all required documents are collected each month. ________________________________________ 3. Designation of Responsibility A Chief Operating Officer has been assigned responsibility for ensuring that all distribution documentation is collected, retained, and reviewed. Program staff and site partners will receive ongoing training to ensure consistent adherence to the updated tracking requirements. ________________________________________ 4. Review and Approval A formal review and approval process has been established. Monthly Distribution Reports will be reviewed by: • The Chief Operating Officer • The Warehouse Manager Any discrepancies or missing documentation will be investigated and resolved prior to monthly reporting. ________________________________________ 5. Monitoring and Follow Up Beginning in 2025, the Organization implemented ongoing monitoring procedures, including periodic internal audits of distribution files. Quarterly compliance reviews will be performed to assess adherence to documentation requirements and to identify additional training needs. The Warehouse Manager will report quarterly to senior leadership on distribution documentation compliance. Management will continue refining the new processes and providing ongoing training to ensure full, consistent adoption across all distribution sites. The Organization anticipates that these corrective actions will fully address the documentation gaps identified in the audit and strengthen internal controls moving forward. ________________________________________ Implementation Timeline All corrective action steps were initiated in 2025, and full implementation of updated procedures is ongoing. The Organization anticipates complete adoption across all distribution sites by December 31, 2026. ________________________________________ Responsible Personnel • Chief Operating Officer-Food Bank Operations: Thomas Deramore • Warehouse Manager-Food Bank Operations: Sean Conner • Chief Financial Officer: Kate Stefan • Executive Director: Timothy Hawkins ________________________________________ This Corrective Action Plan is designed to address the auditor’s findings, recommendations and prevent recurrence of similar issues to ensure compliance with Uniform Guidance documentation standards and internal control requirements ________________________________________ Signature: ________________________________________ Kate Stefan, Chief Financial Officer Community Action Agency of Butte County, Inc.

Categories

Reporting Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1176658 2024-002
    Material Weakness Repeat
  • 1176659 2024-002
    Material Weakness Repeat
  • 1176660 2024-002
    Material Weakness Repeat
  • 1176661 2024-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $359,513
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $132,656
10.766 COMMUNITY FACILITIES LOANS AND GRANTS $123,941
81.042 WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS $115,500
10.187 THE EMERGENCY FOOD ASSISTANCE PROGRAM (TEFAP) COMMODITY CREDIT CORPORATION ELIGIBLE RECIPIENT FUNDS $73,726
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $18,430
93.569 COMMUNITY SERVICES BLOCK GRANT $17,748
97.024 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $6,755