Finding 1181456 (2024-006)

Material Weakness Repeat Finding
Requirement
B
Questioned Costs
-
Year
2024
Accepted
2026-03-19

AI Summary

  • Core Issue: The organization lacks formal procedures to allocate administrative expenses for the TEFAP and CSFP programs, leading to potential misrecognition of revenue.
  • Impacted Requirements: Compliance with federal regulations requires proper allocation of administrative funds for program activities, which the organization has failed to establish.
  • Recommended Follow-Up: Implement quarterly allocation of allowable costs and ensure direct expenses are recorded accurately in the accounting system to align revenue with incurred expenses.

Finding Text

Federal Agency: U.S. Department of Agriculture Federal Program Name: The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative) Assistance Listing Number: 10.568 and 10.565 Pass-through Agency: Hunger Free Pennsylvania (HFP); Pennsylvania Department of Agriculture (PDA); Lehigh County (LC); Northampton County (NC); Carbon County (CC) Pass-through Number: 5-07-39-217 (PDA) Award Period: August 5, 2021 – December 31, 2024 (HFP); October 1, 2021 – September 30, 2026 (PDA, LC, NC, CC) Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: For both CSFP and TEFAP, a recipient agency must use its administrative funds for activities for the administration of the programs. Such activities include but are not limited to transporting and storing USDA Foods within the state or within a recipient agency’s service area, determining the eligibility of program applicants, publishing the times and locations of food distribution, and issuing USDA Foods to eligible persons (7 CFR sections 247.25 and 251.8(e)). Condition: The Organization does not have formal procedures in place to determine the Second Harvest Food Bank expenses incurred during the fiscal year that should be allocated to the TEFAP/CSFP administrative revenue received. The Organization has historically recognized revenue based on when cash is received which is not appropriate. Questioned Costs: None. Context: Management does not have a timely process for determining the allocation of eligible expenses for the administrative revenue received for the distribution of commodities. Management was able to provide a reasonable allocation methodology which was used to create the program expenditure detail for the audit period, however, was provided significantly after year-end. Cause: The Organization experienced turnover within the finance department which resulted in no formal procedures in place for the allocation of allowable costs. Effect: If the Organization does not have timely proper allocation procedures, the Organization could potentially recognize revenue that is not appropriately substantiated with allowable costs and activities in compliance with program requirements. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023- 004. Recommendation: We recommend the allocation of allowable costs and activities be completed at a minimum on a quarterly basis. Also, any direct expenses related to program activities should be recorded to the respective identifying program fund number within the accounting software. The amount of revenue recognized for the programs should be reflected of the expenses incurred up to the administrative funds received from the respective funders. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.

Corrective Action Plan

Significant Deficiency in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative)– Assistance Listing No. 10.568 and 10.565 Condition: The Organization does not have formal procedures in place to determine the Second Harvest Food Bank expenses incurred during the fiscal year that should be allocated to the TEFAP/CSFP administrative revenue received. The Organization has historically recognized revenue based on when cash is received which is not appropriate. Recommendation: We recommend the allocation of allowable costs and activities be completed at a minimum on a quarterly basis. Also, any direct expenses related to program activities should be recorded to the respectiveidentifying program fund number within the accounting software. The amount of revenue recognized for the programs should be reflected of the expenses incurred up to the administrative funds received from the respective funders. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization will implement a standard allocation to be completed on a quarterly basis at the minimum. This process will be reviewed by management to ensure implementation. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 2026.

Categories

Allowable Costs / Cost Principles Eligibility School Nutrition Programs Significant Deficiency

Other Findings in this Audit

  • 1181440 2024-005
    Material Weakness Repeat
  • 1181441 2024-005
    Material Weakness Repeat
  • 1181442 2024-005
    Material Weakness Repeat
  • 1181443 2024-005
    Material Weakness Repeat
  • 1181444 2024-005
    Material Weakness Repeat
  • 1181445 2024-006
    Material Weakness Repeat
  • 1181446 2024-006
    Material Weakness Repeat
  • 1181447 2024-006
    Material Weakness Repeat
  • 1181448 2024-006
    Material Weakness Repeat
  • 1181449 2024-006
    Material Weakness Repeat
  • 1181450 2024-006
    Material Weakness Repeat
  • 1181451 2024-006
    Material Weakness Repeat
  • 1181452 2024-006
    Material Weakness Repeat
  • 1181453 2024-006
    Material Weakness Repeat
  • 1181454 2024-006
    Material Weakness Repeat
  • 1181455 2024-006
    Material Weakness Repeat
  • 1181457 2024-007
    Material Weakness Repeat
  • 1181458 2024-007
    Material Weakness Repeat
  • 1181459 2024-007
    Material Weakness Repeat
  • 1181460 2024-008
    Material Weakness Repeat
  • 1181461 2024-008
    Material Weakness Repeat
  • 1181462 2024-008
    Material Weakness Repeat
  • 1181463 2024-008
    Material Weakness Repeat
  • 1181464 2024-008
    Material Weakness Repeat
  • 1181465 2024-008
    Material Weakness Repeat
  • 1181466 2024-008
    Material Weakness Repeat
  • 1181467 2024-008
    Material Weakness Repeat
  • 1181468 2024-008
    Material Weakness Repeat
  • 1181469 2024-008
    Material Weakness Repeat
  • 1181470 2024-008
    Material Weakness Repeat
  • 1181471 2024-008
    Material Weakness Repeat
  • 1181472 2024-008
    Material Weakness Repeat
  • 1181473 2024-008
    Material Weakness Repeat
  • 1181474 2024-009
    Material Weakness Repeat
  • 1181475 2024-009
    Material Weakness Repeat
  • 1181476 2024-009
    Material Weakness Repeat
  • 1181477 2024-009
    Material Weakness Repeat
  • 1181478 2024-009
    Material Weakness Repeat
  • 1181479 2024-009
    Material Weakness Repeat
  • 1181480 2024-009
    Material Weakness Repeat
  • 1181481 2024-010
    Material Weakness Repeat
  • 1181482 2024-010
    Material Weakness Repeat
  • 1181483 2024-010
    Material Weakness Repeat
  • 1181484 2024-010
    Material Weakness Repeat
  • 1181485 2024-010
    Material Weakness Repeat
  • 1181486 2024-010
    Material Weakness Repeat
  • 1181487 2024-010
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.565 COMMODITY SUPPLEMENTAL FOOD PROGRAM $959,660
10.182 PANDEMIC RELIEF ACTIVITIES: LOCAL FOOD PURCHASE AGREEMENTS WITH STATES, TRIBES, AND LOCAL GOVERNMENTS $858,971
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $203,690
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $188,886
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $159,927
10.187 THE EMERGENCY FOOD ASSISTANCE PROGRAM (TEFAP) COMMODITY CREDIT CORPORATION ELIGIBLE RECIPIENT FUNDS $134,782
81.042 WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS $102,536
93.569 COMMUNITY SERVICES BLOCK GRANT $97,959
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $90,435
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $88,693
97.024 EMERGENCY FOOD AND SHELTER NATIONAL BOARD PROGRAM $59,082
14.169 HOUSING COUNSELING ASSISTANCE PROGRAM $49,345
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $29,774
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $11,893
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $6,142