Finding 1177725 (2025-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-10
Audit: 391133
Organization: St. Louis Area Food Bank, Inc. (MO)
Auditor: ARMANINO

AI Summary

  • Core Issue: Inconsistent documentation procedures led to missing signatures on invoices, indicating a breakdown in internal controls.
  • Impacted Requirements: Compliance with Special Tests and Provisions is compromised, risking noncompliance with federal requirements and affecting inventory accountability.
  • Recommended Follow-Up: Strengthen internal controls through staff training, implement a checklist for documentation verification, and conduct periodic internal audits to ensure compliance.

Finding Text

AL number: 10.568, 10.569, 10.565 AL title: Emergency Food Assistance Program – Food Distribution Cluster Compliance requirement: Special Tests and Provisions Name of federal agency: U.S. Department of Agriculture Name of pass-through entity: Illinois Department of Human Services and Missouri Department of Social Services Type of finding: Significant Deficiency in Internal Control over Compliance of Major Programs Criteria: St. Louis Area Food Bank, Inc. is responsible for implementing and maintaining an effective internal control system over compliance with Special Tests and Provisions. A proper internal control system requires that documentation supporting compliance with program requirements, including inventory distributions, be accurate, complete, and timely to ensure accountability and prevent errors or misstatements. Condition: During the audit, we noted that documentation procedures were not consistently followed. Specifically, two invoice forms of the twenty tested were missing staff signatures. These instances indicate a breakdown in internal controls related to documentation and verification processes. Cause: The deficiencies appear to result from inadequate oversight during intake procedures and high staff turnover, which led to inconsistent adherence to documentation requirements. Possible effect: Failure to complete and retain required documentation compromises the integrity of internal controls, increases the risk of noncompliance with federal requirements, and limits the ability to verify proper food distribution, eligibility, and inventory accountability. Questioned cost: None Recommendation: We recommend that management strengthen internal controls over documentation by reinforcing established procedures through targeted staff training and regular reminders to ensure compliance. Additionally, management should implement a review or checklist process to verify that all required forms are completed and signed prior to finalization. To further enhance oversight, periodic internal audits should be conducted to monitor adherence to documentation requirements and promptly address any recurring issues.

Corrective Action Plan

2025-002: Lack of Operating Effectiveness on Internal Control Over Compliance for Distributions of Food Commodities Corrective Action Plan: Established three checks and balances that are currently in practice: I. Invoices are reviewed by Senior Transportation Manager to ensure signed. 2. Once reviewed by Senior Transportation Manager, invoice is handed off to Partner Services Representative for verification of signatures and electronically scanned into centralized database. 3. Director of Operations reviews all invoices for completion. of signature in database on a weekly basis. Director of Operations uses a control sheet to check against CERES ERP system. Managements Plan: We will continue to monitor and identify any gaps in the CAP outlined above to ensure compliance with appropriate signatures is met. Name of Responsib le Person: Meredith Knopp, Chief Executive Officer Anticipated Completion Date: Implemented effective October 31, 2025

Categories

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring Eligibility Significant Deficiency Equipment & Real Property Management

Other Findings in this Audit

  • 1177708 2025-001
    Material Weakness Repeat
  • 1177709 2025-001
    Material Weakness Repeat
  • 1177710 2025-001
    Material Weakness Repeat
  • 1177711 2025-001
    Material Weakness Repeat
  • 1177712 2025-001
    Material Weakness Repeat
  • 1177713 2025-001
    Material Weakness Repeat
  • 1177714 2025-001
    Material Weakness Repeat
  • 1177715 2025-001
    Material Weakness Repeat
  • 1177716 2025-001
    Material Weakness Repeat
  • 1177717 2025-002
    Material Weakness Repeat
  • 1177718 2025-002
    Material Weakness Repeat
  • 1177719 2025-002
    Material Weakness Repeat
  • 1177720 2025-002
    Material Weakness Repeat
  • 1177721 2025-002
    Material Weakness Repeat
  • 1177722 2025-002
    Material Weakness Repeat
  • 1177723 2025-002
    Material Weakness Repeat
  • 1177724 2025-002
    Material Weakness Repeat
  • 1177726 2025-003
    Material Weakness Repeat
  • 1177727 2025-003
    Material Weakness Repeat
  • 1177728 2025-003
    Material Weakness Repeat
  • 1177729 2025-003
    Material Weakness Repeat
  • 1177730 2025-003
    Material Weakness Repeat
  • 1177731 2025-003
    Material Weakness Repeat
  • 1177732 2025-003
    Material Weakness Repeat
  • 1177733 2025-003
    Material Weakness Repeat
  • 1177734 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $7.94M
10.182 PANDEMIC RELIEF ACTIVITIES: LOCAL FOOD PURCHASE AGREEMENTS WITH STATES, TRIBES, AND LOCAL GOVERNMENTS $2.89M
10.565 COMMODITY SUPPLEMENTAL FOOD PROGRAM $991,890
97.024 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $251,019
10.187 THE EMERGENCY FOOD ASSISTANCE PROGRAM (TEFAP) COMMODITY CREDIT CORPORATION ELIGIBLE RECIPIENT FUNDS $56,387
10.551 SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $54,469
94.006 AMERICORPS STATE AND NATIONAL 94.006 $39,696
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $39,061
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $15,244